ML20210T973
| ML20210T973 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/24/1984 |
| From: | Doyle J Citizens Association for Sound Energy |
| To: | |
| Shared Package | |
| ML20209B909 | List: |
| References | |
| FOIA-85-59 NUDOCS 8606020142 | |
| Download: ML20210T973 (12) | |
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e A'W W kju Y r i ,LuMO g.c )./731RylMhy/fF UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATCMIC SAFETY AND LICENSING BOARD In the Matter of l 1 TEXAS UTILITIES GENERATING l Docket Nos. 50 445-1 COMPANY, et al. I and 50-446-1 i (Comanche Peak Steam Electric Station i Station, Units 1 and 2) l CASE'S ANSWER TO APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO CENUINE ISSUE RECARDING CONSIDERATION OF LOCAL DISPLACEMENTS AND STRESSES in the foru of AFFIDAVITOFCASEWITNESSkACKDOYL v - I. Zero Clearance Box Frames
- 1. Applicants state:
"In the absence of quantitative code guidance, Applicants employed a ccuservative methodology for select'.ng all3wables for assessing the localized pipe stresses. These allowables are approximately 60" of the allowables which normally would be applied, i.e., three times Sm.
(Finneran Affidavit at 4.)" I disagree with Applicants' statements. The Applicants have defended the box frame concept for supporting pipes since the time of my deposition in August 1982 fif, l at which time I pointed out two problems with this concept: See CASE Exhibits 669 and 669A, Deposition / Testimony of [ack Doyle, and fJlf CASE Exhibit 669B, Attachment toDeposition/TestimonyofQackDoyle 8606020142 860328 1 F0lA-85-59 PDR FOIA GARDE 83-39 pop
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F o . (1) It restrained thermal growth of the pipe; and (2) It represented an unstable structure. During the September 1982 hearings, with the aid of models I demonstrated the instability factor. Beyond this, by the use of simplifying equations, I showed that the forces exerted on the box frame were on the order of 28,000 lbs. or 14 cons. The Applicants and their agents, and in fact, the NRC Staff, have steadfastly stated that this configuration presented no problems. They are not quite sure why this is so, but we must commend them on their persistence if not their technical competence. I state this because each time they offer an absolute proof showing the ability of the system to withstand the forces exerted by the pipe, they either get shot down or blow off their own foot. But rather than backing off,
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they merely come forward with yet another absolute proof. A few examples of this proof-of-the-month effort are as follows: (1) There is no thermal problem because the frame does not actus11y have a zero inch gap f2/. The NRC Special Inspection Team (SIT) was quite proud that the Applicants had informed them of this avenue of escape. Beyond this, Applicants had physically measured a number of box beams and announced that they had found that gaps in fact had existed. However, CASE pointed out that this condition ensured instability, s at page 34 f2/ See NRC Staff Special Inspection Team (SIT) Report, 2 1
I (2) Applicants' agent, Cygna Energy Services, proceeded to prove that there was no problem with these box frames by utilizing the most sophisticated method of analysis (finite element); however, their efforts only proved that there were serious problems with this clamping system f3/. Beyond this, although Cygna was less than satified with some of the results of finite element analyses that they had accomplished, they conceded that the excessive forces indicated by the modelling for box beams in this finite model were likely to be more accurate than some of the others f4/. However, undaunted by these f ailures, Applicants have now unveiled their latest final absolute proof. But hold your plaudits, for what we have here is yet another example of the deceit and/or stupidity of those "somewhat knowledgeable" engineers for which Applicants have achieved legendary status in their own time. For this final absolute beyond-the-shadow-of-a-doubt proof, Applicants of fer Attachments A, B, C, and D to 'their Motion for Summary Disposition, which are so flawed as to be rendered useless. For example: l Referring to Attachment A: (1) At page 1 of calculation SI-1-325-002-S32R, Applicants state:
"If air film insulation effect is considered, actual tube temperature will be much higher. Thus, this approach is very conservative."
/3/ See Tr. 12,710-12,712, 12,724-12,725.
f4/ See Tr. 13,086. 3
I would have thought that even Applicants' somewhat knowledgeable engineers would not attempt to reverse the laws of thermal transport, for the fact is if the air film is considered, the box beam temperatures would be much lower, not much higher as stated by Applicants. The pipe wall temperature at the interface between the outer wall of the pipe and the surface of the air film would be higher, but not the tube interface, since there is an additional layer (air film) between the pipe and the box frame. (2) The above point is relatively minor when compared to the fatal error which appears on page 2 at (2) of the calculation. While it is a fact that due to contact between the pipe and the box beam thermal transfer will occur, it is not true that the full length of the tubes making up the box beam will experience the same temperature gradients as was calculated for the tube width resulting from line contact. Any temperature from Applicants' procedure would exist only at a point directly opposite the line of contact. l (3) Because of the temperature gradient between the inner and l outer surface of the box frame, the box frame will not expand 0.01359 inches as assumed by Applicants but will in fact i expand in an indeterminate manner to a far less degree. l Additionally, as a result of the differential expansion of 1 I l 4 l
F 4 the two surfaces of the tubes making up the box beam, there will be new internal thermal stresses generated which were not considered by Applicants. (4) The fact is that the thermal gradient is not linear as indicated by Applicants. See CASE Exhibit 669B, Attachment to Deposition / Testimony of Jack Doyle, graphs generated through tests by ITT Grinnell, items 13E through 13J. This would result in actual box frame stresses that are somewhat higher than assumed by Applicants' considering direct bending only as a result of thermal constraint. (5) Another point associated with Applicants' attempt to supplant logic wih the appearance of logic may also be found on page 2 (2). Young's Modulus is stated to be: 6.387 times 10 to the
-6, whereas the AISC states at 6-11 that Young's Modulus is approximately (6.1 + .0019 times the temocrature) times 10 to the -6, or 6.486 times 10 to the -6, and this would be the value used in the analysis of a warehouse, not the lesser value used by the Applicents.
Collectively, these deviations from engineering fundauentals listed above become frightening when one finds that the wide band of reliability which existed prior to the inclusion of thermal expansion effects has been dangerously erroded. For example, Applicants at page 8 of 11 indicate that the stress levels for equation 11 are: 39169 divided by 44000 = about 90%. However, the reality is that when 5
f~ properly analyzed, the pipe fails to meet the codes. When considering this single problem, one must be aware that there are other contributors to this problem which have not been addressed. For example, the mass of supports supported by the pipe, the stiffness effects, etc., all could result in higher mechanical loads, and are being independently addressed elsewhere. This manicuring of standard procedures will always occur when somewhat knowledgeable engineers are allowed to justif y multiple problems on a point-by point basis with each justification being > offered independent of all other concurrent problems. If the principle of uncoupling of problems were acceptable procedure, it would have been accepted years ago as a means of reducing the cost of all types of construction. I have come to the conclusion,'after almost two years of shooting at moving targets thrown up by the Applicants, their agents, and in fact the NRC Staff, that the American system of jurisprudence is not the proper forum for determining the reliability of nuclear power plants. Should the Board accept the procedures utilized by Applicants to justify construction which was initiated by somewhat knowledgeable engineers based on their judgement in lieu of technical expertise, then the Board must be prepared for the conser ences. Acceptance of these concepts offered by the Applicants will establish precedent legalizing the approach of constructing facilities without attention to fundamentals and codes and then at a later time justifying this f ait accompli. And this will apply on a national basis, not strictly to Comanche Peak. 6
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f-i l l I didn't waste my time dissecting all of the caterial accompaying Applicants' Motion for Summary Disposition on this subject, since I believe that the points made on Attachment A are suff.cient i to show the methodology that Applicants have used throughout these. hearings. Beyond this, it is appalling that for almost two years it has been Mark Walsh and I that have rooted out the fallacies of Applicants' afferings, while the NRC Staff not only have failed to perform their mission to protect the public health and safety, but have in fact been joint participants in these devious games played by Applicants.
- 2. Applicants state:
"There are 51 zero clearance box frame supports at Comanche Peak.
(Finneran Affidavit at 4.)" See answer 1 preceding.
- 3. Applicants state:
"Orly one c.ero clearance box frame is located on a piping run with a maximum water temperature greater than 200 degrees F. This is support SI-325-002-S32R. The maximum temperature of the pipa. in this esse is 350 degrees F. (Finneran Affidavit at 4.)"
See answer 1 preceding.
- 4. Applicants state:
"Even when including the local stress induced in the frame from the thermal expansion of the pipe with other loads, all stresses in the frame on support SI-325-002-532R are less than Code allowables. The 7
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I loads and stresses in this support would be greater than those - encountered in the other supports of this type because of the higher temperature of this pipe and the fact that the pipe is stainless steel (resulting in greater pipe expansion), and the greater thickness of the pipe (affording less flexibility and, thus, imparting greater loads). (Finneran Affidavit at 4-5.)" See answer 1 preceding.
- 5. Applicants state:
"All stresses in the pipe are also less than the conservative allowables Applicants employ for assessing localized pipe stresses.
(Finneran Affidavit at 5.)" See answer 1 preceding.
- 6. Applicants state:
"Cygna also peformed an analysis (finite element) of the frame on this support. Their analysis demonstrated that the stresses in both the pipe and the box frame remained well below allowables even when both thermal and mechanical loads were combined. (Finneran Affidavit at 5-6.)"
See answer 1. preceding. I
- 7. Applicants state:
" Applicants conservatively calculated the loads between the frame and
( the pipe for the support cited by CASE in its Proposed Findinga (p34e l IV-17) on this topic. That analysis demonstrates that the cesulting force between the pipe and the frame will be 454 lbs. CASE had l estimated, using a very simplified calculational technique (CASE l Proposed Findings at IV-17), that the laod created between the pipe and the box frame was 27,280 lbs. (Finneran Affidavit at 6.)" See answer 1. preceding. 8 e
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II. Anchors
- 8. Applicants state:
" Applicants performed a conservative analysis of the anchor supports referenced in Section 14 of CASE Exhibit 669B f or which CASE claimed the radial thermal expansion of the pipe should have been calculated.
Inclusion of the thermal expansion ef fects of the pipe with other loads in the assessment of the anchors led to no overstressed conditions. (Finneran Affidavit at 8.)" See answer 1 preceding.
- 9. Applicants state:
"Cygna anal zed a similar support for these same ef fects in their response to y15) Question 15(seeTestimonyofNancyH. Williams, Board April 84 Ex. 1 at 33.) These results demonstrate that all stresses in the frame and baseplace were f ar below the allowables used by Cygna. (Finneran Af fidavit at 7-8.)" ,
See answer 1 preceding. - III. Tube Steel Walls
- 10. Applicants state:
" Applicants' practice regarding the assessment of local stresses in tube steel walls is for each support design organization to assess the effects on a case-by-case basis, when deemed appropriate by the engineer. The NRC Staff reviewed Applicants' practices in this regard and had no concern regarding the adequacy of Applicants' approach. The Staf f reviewed a random sample of 100 vendor cer:ified eupports selected by the Staff and found Applicants had considered these local effects. (Finneran Affidavit at 9.)"
See answer 1 preceding. 9 W g
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- 11. Applicants state:
" CASE performed no calculations to substantiate its assertions on this issue. Rather, CASE presises its position on certain factors it believed indicated that analyses should be performed. First, CASE incorrectly implies that the minimum width ratio of tube steel to tube steel connections that Applicants used (until September of 1982) was 0.8. Next, with respect to CASE's assessment of the local stresses in the support referenced in its Proposed findings, CASE claims that the tube to tube ratio was less than .4. The connection ratio is actually
.562$. Finally, the actual stress for this connection is 2261 psi, or 57% of the applicable allowable. Thus, contrary to CASE's assertion the design of this connection is clearly adequate. (Finneran Af fidavit at 10-11. )"
See answer 1 preceding.
- 12. Applicants state:
" Applicants selected several worst case supports from CASE Exhibit 5695 with tube steel connection ratios less than 1.0., and included three additional supports claimed by CASE to have been inadequately desi,gned with respect to local ef fects of welded attachments to tube steel, for detailed local f ailure analysis. In all cases the . local stresses were less than allowables. (Finneran Affidavit at 11-12.)"
See answer 1 preceding. IV. Lecal Deflections and Deformations
- 13. Applicants state;
" Applicants' practice regardicg consideration of local deflections and deformations is standard industry practice which is premised on sound engineering principles that result in adequate support designs.
Applicants' practice is to consider the deflections of the structural portions of each support in calculating deflections for comparison to the 1/16" deflection guideline. (Finnetan Affidavit at 13.)" See answer 1 preceding. 10
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I 14, Applicants state:
"To assess these effects, Applicants selected the 15 supports from CASE Exhibit 669B which present worst case conditions, and a support used by CASE in the cross-examination of the staff on this subject.
Applicants' analyses demonstrate that even when local and component effects are accounted for in deflection calculations, their deflection criterion is still satisfied in the vast majority of cases. In those cases where the deflection does exceed 1/16" (and none greatly exceeded the criterion), the support stiffnesses remained in the acceptable range. Thus, although these local effects may result in potential deflections slightly greater than 1/16" there is no safety significance to this fact. (Finneran Affidavit at 13-16)." See answer 1 preceding.
- 15. Applicants state:
" CASE incorrectly alleges that Applicants' support designs will have
'large deformations' and, thus, Applicants have not satisfied the guidance contained in the Regulatory Guide 1.124 However, Applicants' practice regarding Class 1 supports (to which the Regulatory Guide applies) is to perform complete stiffness calculations, including consideration of local effects. (Finneran Af fidavit at 16.)"
See answer 1 preceding.
- 16. Applicants state:
" Irrespective of the support classification, the discussion in Regulatory Guide 1.124 regarding large deformations is related to the use of plastic analysis methods. With respect to support design using elastic analysis, as Applicants use, Regulatory Guide 1.124 recognizes that defctmations will, in fact, be small. (Finneran Affidavit at 17.)"
See answer 1 preceding. 11
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.
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t b UNITED STATES OF AMERICA NUCLEAR REGULATCRY COMMIS5ICN BE:0RE THE ATCMIC SAFETY AND LICEN5?f!3 BCARD In the Matter Of j i TEXAS UTILITIES GENERATING l Occket Ncs. 50 445-1 CCMPANY, et al. and 50-446-1 (Ccmanche Peak Steu Electric Statien Station, Units 1 and 2) l CASE'S PARTIAL ANSWER TO APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WICH THERE IS NO GENUINE ISSUE REGARDING ALLEGATIONS CONCEF3ING CONSIDERATION OF FORCE DISTRIBUTION IN AXIAL RISTRAINTS in the form of AFFIDAVIT OF CASE WITNES ARK WALSH
- 1. Applicants state:
" Applicants' design approach for modelling trape e type supports with trunnions is to model the support as a single support acting in ene axial direction. (Affida"it at 3.)"
I agree with Applicants' ststem*nt, although their philosephy Ls wrong and this is not what they told the NRC Special Inspection Tean (SIT), as will be discussed in answer 2 following.
- 2. Applicants state:
" Applicants' tacdelling technique is reasonable. The modelling technique urged by CASE Gould be very censervative and not necessarily a more realistic teodelling technique. (Affidavit at 3-4.)"
I disagree with Applicants' statements. The Applicants' present s FCnA-85-59 b d g(i (
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J t modelling technique does not take into account the rotational restraint provided by these supports that are welded to the pipe, which CASE has argued should be considered and which the Applicants' cold the SIT they were going to do. According to the SIT (as discussed on page XVII - 6 of CASE's Proposed Findings f1/):
"The Special Inspection Team concluded that the rotational stif fness associated with these designs should have been included in the piping stress analysis. Subsequent discussions with the Applicanc indicated that this rotational restraint had also been id.en'cified during the Appl,1 cant's normal design review and that
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the pipe stress analysis was beine modified to consider this rotational restraint. The Special Inspection Team reviewed the prcposed method of analysis (' Minutes of discussion at the Meeting
' bet';sen G&H and NPSI on March 17, 1982') and concluded that the method of codeling the rotational restraint and ths. attendar.t loads on the snubbers was acceptable. Since the Acolicant is includine this rotational restraint in th,e pie, stress analvsis, the Spe.cial Inspection Team foynd the concern on nonent restraints introduced in the piping system to be resolved." (Ecphases added.)
Since the. Applicants informed the SIT that they were going to go back and take the c0tational restraint into account in the pipe stress anglysis, the S!I closed this item -- baspd en the fset that Applicants al'aady e knew about the problem and the Applicants' repr6sentagion that they were going to do it. In addition, the Applicants told this Board as part of their Plan (Icen 15) f;/ that they wouldt 11/ This pro'cles was addressed in detail in Section XVII of CASE's 8/22/83 Proposed Findings of Fact and Conclusions of Law (Walsh/0oyle Allegations).
/2/ See Applicants' Plan to Resppnd to hemorandue and Order (Quality Assurance for Design), February 3, 1984 S_ee also Footnote 1, page 2, of the Motion being answered here, Applicante' 7/9/84 Motion for Sy(amary Disposition Ragarding Allegations Concerning Consideration of Force Distribution in Axial Restraints.
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" provide evidence of how the design has accounted for the ~
torsional resistance cf axlal restraints. This evidence will be generated through the performance of analyses." However, in their Affidavit (at pages 3 and 4), Applicants are now saying that they don't have to account for the torsional resistance of axial restraints:
". . . the rotations are verv small and accommodated by the olav in the two less of the sucoort. Moreover, when seismic analyses are performed using the resoonse soectrum nethod, as is the case at CPSES, the resulting support loads are not dependent on the relative phase between the response motiens, i.e., the axial and rotational motion. In fact, modelling of the rotational constraint of the support using a response spectrum analysis would always add the peak of the response load resulting from the axial motion to the peak of the response load resulting from the rotation. Therefore, this modelling technique would be very conservative and not necessarily a more realistic modelling technique. Consequently, Aeolicants believe that modelline the restraints in cuestion as purelv axial restraints is adecuate."
(Emphases added.) What the Applicants have stated in their Affidavit is contrary to what they had told the KRC SIT and this Licensing Board through their "get well" Plan. The Applicants claim that the rotations are small and are accommodated by the gaps within the support and that they don't have to consider the rotations. During the 7/3/64 Bethesda meeting betueen the NRC Staff and Cygna, there was a discussion regarding Applicants' use of welded attachments (see 7/3/84 meeting Tr. 18-43 -- I urge the Board to read this entire transcript portion). Mr. Tereo of the NRC Staff discussed the Staff's concerns in this regard and mentioned NUREC/CR-2175, especially with regard to unequal load distribution (Tr. page 27). He , A 3 E further indicated that as a result of the testing performed (reported , in NUREG/CR-2175), the NRC Staff revised its Standard Review Plan, Section 393, to address this issue; he further stated (Tr. page 28) that the July 1981 Standard Review Plan states:
"The snubber end fitting clearance and lost motion must be minimized and should be considered when calculating snubber reaction loads and stresses which are based on a linear analysis of the system of component."
CASE obtained a copy of NUREG/CR-2175 (it was not received until 8/25/8*, so I have only quickly scanned portions of it). As indicated in Attachment A hereto (applicable portions of NUREG/CR-2175), it is stated (page 15 of NUREG) that:
". . . a linear analysis may be made provided the total clearance is-less chan .05 inch, and the load and stresses are multipliled -
by the appropriate load factors. Snubber reaction loads and stresses shall be increased by 100% for clearances greater than .0 but less than .02 inch. Snubber reaction loads and stresses shall be increased bv a factor of 4 for clearances greater or equal to --
.02 inch but less than .05 inches. Detailed nonlinear analvsis _
is recuired for systems with .05 inch or greater clearance." (Emphases added.) For the Board's info'rmation, the clearance is defined in Appendix B of the NUREG (Attachment A hereto, page 84), which states, in part:
"The support clearance is the summation of individual gaps existing between snubber, backup support structure and the center of gravity (or geometry) of the component being supported. The total gap shall not exceed .05 inch." (Emphasis added.)
CASE hrs already submitted (on 8/13/84) a response to the Applicants' Motion for Summary Disposition Regarding the Effects of - Caps on Structural Behavior Under Seismic Loading Ccaditions. In response to the Applicants' state =ent that " Identifying the effects of 4
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. t gaps by comparison of the results of nonlinear time history (with gaps) .
and response spectrum (without gaps) analyses is difficult," I suggested using a friction type connection (page 24 off 1sh{} Affidavit). It would appear from this NUREG that the Applicants should be required to perform a detailed nonlinear analysis because of the gaps or go to friction type connections, as I have recommended. In addition, the small gaps on which the Applicants rely to dismiss the rotational restraint provided by the support in the pipe stress analysis can cause additional problems which the Applicants have not addressed, as discussed above.
- 3. Applicants state:
" Applicants evaluared the significance of the effects CASE alleges should be considered by reanalyzing several piping stress proble=s utilizing the modelling assumptions CASE would have Applicants employ.
These analyses demonstrated that Applicants' assumption of excluding the rotational restraint of the trapeze support from the analysis has virtually no effect on pipe stresses. (Affidavit at 4-5)." There are virtually no effects on the pipe stresses, as the Applicants have stated, assumine none of the snubbers or struts exceeds it; allowables and assuminz that Applicants have done their analyses correctly (assunptions with which I do not agree). When a snubber or strut exceeds its capacity, an additional moeent is created within the pipe since the support is not acting through the centerline of the pipe but is offset due to the welded trunnion. This additional moment was not considered by the Applicants in their Affidavit. 5
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J l 4 Applicants state: .
"Applicantr' analyses demonstrated that chan'ges in loads on the so'pports on the reanalyzed stress problems occur only with respect to the' traper.e su'pports themselves. This effect is exp3cted in that modelling the rotational constraint of the support will produce an additional load on each side of the trapeze which had not been previously analyzed. These additional loads did not exceed applicable allowables. (Affidavit at 5-6.)"
I agree with Applicants' firs't sentence, with the same qualifications as discussed in answer 3 preceding. Regarding Applicants' second sentance, the Applicants state "which had not been oreviously analyzed." I thought these supports were as they were originally designed, and not containing any additional moments. If there were a problem, the Applicants are committed to resolving that problem in a promet manner. The Applicants informed the SIT that thev were zoing to take the rotational restraint into accoun, as part of their as-built stress analysis f3/. By reviewing Table 3 attached to Applicants' Af fidavit, one can immediately see that, when the rotational constraint analysis is used, the load can almost double. This analysis had not been considered (to the best of my understanding) prior to Applicants' current Motion for Summary Disposition. Gary Krishnan testified (incorrectly) that I was told in the past that it was not my responsibility to address the issue of welding of stanchions to pipes by NPSI, IIT Grinnell and PSE. Mr. Krishnan told me that they did not intend to include censideratloa of the welded stanchions f4/. f3/ See Applicants' Exhibit 142, pages 25-26; NRC Staff SIT Report, NRC Staff Exhibit 207, pages 38 and 39; and discussion at page XVII - 5 of CASE's Proposed Findings. f4/ See discussion at pages XVII - 2 and XVII - 3 if EASE's Proposed Findings. 6 L
1 i l 1 6 The Applicants state that these additional loads did not exceed applicable allowables, but what are they using as an allowable stress? The answer is that they have tripled the allowable stress based on a misconception that the seismic rotation producing the load is a secondary stress (Applicants' Affidavit at page 7). Therefore, when the load doubles, the Applicants have tripled the allowable, and have found no overstressed conditions, which seems very understandable, given their methods. The Applicants are in error. This is not a secondary stress and the allowables cannot be increased by a factor of
- 3. Cygns agrees with me regarding this, as stated in their Autust 10.
1984 letter to TUCCO [5/, where they state, in part:
" Based on a review of that document (Applicants' Motion for Summary Disposition on axial restraints), Cygna does not agree with the interpretation' that the rotational constraint provided by the double trunnion tr.apeze supports constitutes a condition of restraint of free end displacement. And, therefore, an increase in the allowable stress for these supports is not appropriate."
Therefore, Applicants' statement that the additional loads did not exceed the allowables is undocumented and ic based upon a false premise of increasing the allowable.
- 5. Applicants state:
" Applicants evaluated every Unit I and common double trunnion support employed at Comanche Peak for these effects. That analyses (sic) demonstrated that the total loads imposed on each side of the trapeze supports would be acceptable, i.e., in no case were Code allowables exceeded, when the additional loads were factored into the support design. (Affidavit at 6-8.)"
/5/ See CASE Attachment 3, 8/10/84 letter from N. H. Williams, Project Manager, Cygna Energy Services, to J. George, Project Manager, TUCCO.
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r See answer 4 above. In addition, on August 22, the Applicants . provided to CASE on discovery (requested 8/6/84 /6,/) one pipe support drawing and pattial calculations which, according to Applicants, included the maximum difference in loads with and without consideration of the rotational constraint (see Attachment C hereto). On page 1 of 2 of Attachment C, dated 6/14/84, near the middle of the page there is a Table. Above the Table there is a ratio of the old load vs. the new load. The ratio of 1.459 which is shown in the top portion of the calculation is apparently in error. The load due to the moment restraint of the pipe is listed as 142 kips. The original load divided by 2 (for one of the stanchions) is shown to be 97.329 kips. The ratio should be 142 plus 97.329 divided by 97.329 = 2,45, a considerable difference. In the Table, under Bolt Tension, the new load appears to be obtained by multiplying the existing load by the ratio of 1.459. For example, bolt 6 had an existing tensile load of 26192.38 lbs. The new load is 26192.38 times 1.459 = 38213.87 lbs., as is shewn in the table. But using the correct ratio of 2.45, the tensile load in bolt 6 is 26192.38 times 2.45 = 64170. (rounded) lbs. Under bolt shear for bolt 6, the existing load is 18657.21. The now load using Applicants' figures should be then, 18657.21 times 1.459 = 27221. lbs. (rounded off because I don't think including the 1/100 of a lb. will offset the 27,000 lbs. slready calculated). But
/6/ See Applicants' 8/22/84 letter to CASE from William A. Horin, Counsel for Applicants, page 1, item 3.
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apparently the Applicants have a'new way of figuriTg their shear loads. . They use & new method called " redistribution" (see fifth column of tab,le) . ' Not considering this " redistribution," the correct shear load
- s would be 2.45 times 18657.21 = 45710. lbs. This is over three times greater than what the Applicants arrived at. r The insert allowable (shown at the sottom of the page, left),
according to the Applicants' PSE Guidelines, is 25 kips for tension and 25 kips for' shear (see CASE Exhibit 724, admitted at Tr. 6471, copy attached). The calculations do not show justification for Applicants' doubling,the allowable shear load for the insert (as shown in
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' / Attachmend C). It is apparent that the cortect tens,ile load bv itself will exceed the allowable.
Ths Applicants have also listed the allowable tensile and shear capacities of the A193 high strength bolt in the attachment as 90 kips in tension and 42.4 kips in shear. The Applicants have shown in their_' PSE Guidelines (CASE Exhibit 724) the allowable tensile capacity for an A193 bolt as 66 kips (working load), and in shear, the working load is 34.5 kips.' Regulat'ory Guide 1.124 (CASE Exhibit 743, ad=1tted at Tr. 5901, copy attached) does not permit Applicants to increase the allowables in-this manner. It states, in part (page 1.124-2, B.1.b):
" Allowable service limits for bolted connections are derived from tensile and shear stress limits and their nonlinear interaction; they also change with the size of the bolt. For this reason, the-increases permitteo by NF-3231.1, XVII-2110(a), and F-1370(a) of
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Section III are nqt directly applicable to allowable shear stresses and allowable stresses for bolts and bolted connections." e d 4
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- 6. Applicants state: , j "With respect to lug-type restraints, it is neither necessary nor reasonable to expect that the lugs can be installed in a perfect circumferencial plane with zero tolerance. The lugs have been installed within reasonable limits. ( Af fidavit at 10-11.)"
This is where the Applicants ara wrong -- again. The procedure in question recuires zero tolerance in construction, according to their own Affidavit. In their Affidavit at the bottom of page 9, Applicants represent that CASE asserted that the method employed by ITT Grinnell to determine the loading distribution in axial restraints is inadequate. To be more accurate, as CASE has stated before, ITT Grinnell's method "is a gross error for practical engineering, although the method =ay be academically correct" /7/. _ As the Applicants went out in the field and verified, perfection in construction is not achievable. But the analysis which Applicants had chosen to perform recuired perfection in the field. This topic was never disputed by the Applicants or the NRC Staff prior to this Motion for Summary Disposition, as stated in CASE's Proposed vindings, page x11 - 6, third full paragraph. It appears that the lugs were installed without anv OC orocedures as to the acceptable tolerance (gap) between the lug and the supporting surface, and therefore any size of gap could exist in the field. Il/ see cast's Proposed vindings, dottom of page x11 - s, continued on x11
- 6).
10
- 7. Applicants state:
"The stresses which may occur in the pipe, lug or frame as a result of differential engagement of the lugs will be localized. These potential local deformations would be self-limiting and readily redistribute the load to other lugs. Only one other lug need be engaged to fully resist the entire load which may be imposed. (Affidavit at 10-11.)"
The Applicants are assuming that, of the four lugs, two lugs are always engaged. This may not be the case. Due to construction, there may be a large gap (greater than 1/16") and due to pipe rotation, the total load may be on just one lug. Since the lug was only designed to carry one-half the load and is now receiving the total load, the pipe stress analysis needs to consider this condition. The self-limiting deformations have already been included in the ASMI code, and therefore they don't have any more room to play with the numbers. I.n summary, the Applicants did not have a QC program to verify the gaps which now exist in the field, used an improper and impractical design analysis, and are now attempting to justify these cumulative errors.
- 8. Applicants state:
"It f.s assumed that loads will be transmitted to the lugs furthest from the support anchors, the frame deflection can be larger than initially assumed. However, both frame deflection and rotation of the pipe will act to close the gap to opposite or adjacent lugs. (Affidcvit at 12.)"
The first sentence is not complete. However, in reviewing the Affidavit, it appears that the sentence should read, "If it is assumed
. . . ", etc. There is no documentation to support any of Applicants' many assumptions contained in these stacaments.
11
Further, as has haopened before in Aeolicants' Statements of , Material Facts As To Which There Is No Cenuine Issue f8/, whoever prepared the Statements of Material Facts has (whether deliberately or inadvertently) altered the meaning of the sworn Affidavits of Applicants' witt e sect. In this instance, words have been added which are not containe:d in A>plicants' Af fidavit (which is referenced as the source of the Statemen:s of Material Facts). In this instance, the Statement of Material Facts states:
"However, both frame deflection and rotation of the nice will act to close the gap to opposite or adjacent lugs. (Affidavit at 12.)" (Emphases added.)
But nowhere on page 12 of Applicants' Affidavit does it state that rotation of the pipe will help close the gap to opposite or adjacent lugs. Applicants have again misquoted their own Affidavit. This is very misleading, lecause it means that not only CASE, but the Board cannot depend upots the Statements of Material Facts to be accurate, and must read each and every word of the accompanying Affidavits to be certain what the witnesses are actually saying. In fact, rotation of the pipe could offset any deflection of the frame which was initially assumed to tend to close the gaps to the other lugs; this is discussed in the Affidavit. Further, rotation of the pipe could even tend to ocen gaps and transfer the load back to the outboard lug; this is not discussed in the Af fidavit.
/8/ See discussion at page 8 of CASE's 8/13/84 Answer to Applicants' Statement of Material Facts As to k'hich There Is No Genuine Issue Regarding CASE Allegations Regarding Section Property Values.
12 l l
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Also (as CASE has previously demonstrated -- see page XII - 7 of - CASE's Proposed Findings), the frame will indeed experience larger stresses than would otherwise be computed on the basis of two lugs . sharing the load -- which ijt discussed in Applicants' Affidavit at page 12.
- 9. Applicants state:
"Two conditions may exist with respect to lug-type supports, viz., (1) the lugs may be stronger than the frame (and thus greater frame deflection will result) and (2) the frame may be stronger than the lugs (inducing small deformations in the lug until other lugs are engaged).
(Affidavit at 12-13.)" I agree with the concept if one assumes that all the stresses are within the allowables and the application of the loads due to static cr
~
dynamic motion can always be accurately anticipated. As will be shown below, the method used by the applicants is not consistent with the original design assumptions.
- 10. Applicants state:
"For the case in which the frames are weaker than the lugs, Applicants performed a study of idealized frames loaded axially using the four lug arrangement. These cases represent the range of deflections which may occur in the field and, thus, provide evidence of the ability of the frame to deflect to permit engagement of additional lugs. Only in the second case was it found that a deflection which could (slightly) exceed Applicants' deflection guideline may be required to bring a second lug in contact with the fra=e. However, any excess loads would be self-limiting and thus when the load is shared by the second lug the deflection no longer increases for a given load. ( Af fidavit at 14-15.)"
13
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The study which is referenced by Applicants has two major flaws. , The first one, as discussed in answer 8 preceding, is that the Applicants neglected to co'nsider the rotation of the pipe. The rotation of the pipe would increase all loads and stresses which the Applicants have referenced. The second item is that the Applicants are now relying on a plastic analvsis, which is not consistent with their original analysis which was a linear elastic analysis which they are supposed to use. The allowable stresses which the Applicants are committed to use for these types of supports are discussed in ASME Appendix IVII, 2000, which is for a linear elastic analysis. In addition, the Applicants have not shown that, with their , plastic design philosophy, the supports would be capable of sustaining cyclic loads. I believe that the plastic design which they are demonstrating is for a one-time event, and therefore is not applicable to those loading conditions that are repetitive.
- 11. Applicants state:
"To assess the condition in which the frame is stronger than the lug and, thus, lug localized yielding may occur, Applicants analyzed the effect of the maximum localized yielding in the lug and the pipe surface which could occur to bring the additional lugs in contact with the frame. This analysis was performed using a non-linear finite element technique and the computer program NASTRAN. The result of this analyses (sic) show (sic) that minimal plastic strains, entirely localized at the surface of the pipe and the welds permit a 1/16" deflection from the lugs with no adverse consequence to the lugs. With respect to the, stresses on the pipe, Applicants' analysis demonstrates that they would also be acceptable. (Affidavit at 15, Attachment 2)."
14
- . l A.
As stated before, the use of the nonlinear finite element program . is not consistent with the original design and the Applicants did not provide documentation to show cyclic loads would be acceptable. The Applicants' procedure for verifying the lug capacity also did not consider the fact that only one lug may, in fact, be carrying the total load since no tolerance was provided for QC to check. It should be noted that I have not had time even to scan the transcript of the 8/6/84 Applicants /NRC Staff / CASE telephone conference call (Mr. Doyle was not on that call), the transcripts of the 8/8/84 and 8/9/84 Bethesda meetings between the NRC Staff and the Applicants, (all of which were just received by CASE on 8/22/84), and, of course, the transcript of the meeting held at Comanche Peak 8/23/84 between the NRC Staff and the Applicants. Also, it is my understanding that there will be some changes (at least one substantive) to some of Applicants' Affidavits regarding some of the Motions for Summary Disposition and that by 8/30/84 the Applicants are to provide the Staff with several documents relating to the Motions for Summary Disposition (which obviously we also need to adequately answer Applicants' Motions). I would have liked to be able to do a more thorough job, and would like to be able to supplement my testimony after I have had a chance to review the referenced transcripts, changed Affidavits, and additional documents. 15
~
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l l l Attachments: Attachment A NUREG/CR-2175, pages 15 and Appendix B, page 84 -- see page 4, answer 2 Attachment B 8/10/84 letter from N. H. Williams, Project Manager, Cygna Energy Services, to J. George, Project Manager, TUGC0 -- see page 7, answer 4 Attachment C Drawings and partial calculations of Support FW-1 703-CS2R -- see page 8, answer 5 CASE Exhibit 724 PSE Guidelines, Section VI, Richmond Inserts & Anchor Bolts Stress Allowables, Rev. 3, page 1 of 2 -- see page 9, answer 5 CASE Exhibit 743 NRC Reguistory Guide 1.124, Revision 1, January 1978,
" Service Limits and Loading Combinations For Class 1 Linear-Type Component Supports" -- see page 9, answer 5 e
16
The preceding CASE's Answer to Applicants' Statement of Material Facts As To Which There Is No Genuine Issue was prepared under the personal direction of the undersigned, CASE Witness krk Walsh I can be contacted throughCASEPresident,hs.JuanitaEllis,1426S. Polk, Dallas, Texas 75224, 214/946-944 My qualifications and background are already a part of the record in l these proceedings. (See CASE Exhibit 841. Revision to Resu=e of Mark Walsh, accepted into evidence.at Tr. 7278; see also Board's 12/28/83 Memorandum and
. Order (Quality Assurance for Design), pages 14-16.)
I have read the statements therein, and they are crue and correct to the best of my knowledge and belief. I do not consider that Applicants have, ir their Motion for Summary Disposition, adequately responded to the issuesraisedbyCASEWitnesshekDoyl and me; however,'I have attempted to comply with the Licensing Board's directive to answer only the specific state =ents made by ApplLeants. _ I f (Signed) Mark Walsh ---- L_ m STATE OF TEXAS : On t is, the #7 - day of hu6a , 1984, personally l appeared k Wals hun to =e to be thej person whose name is subscribed to the foregoing instrerent, and acknowledged to me that he executed the ~ same for the purposes therein expressed. , Subscribed and sv6,rn before me on the A 7
- day of Cw6'us 1984 V'
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. Yotary Public in and for the SAMUEL. p g exas h
My Commiss;on Expires My Com=ission Expires:j 13185 Y
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Deve1.c C in'e tutice eith will provide the basis fer strvCtural analy- l til and desigf1 rules for tyttm and CCrTaeents W8tiCh utillie inubbers 45 Sut?crts. Result % will be u'.ed to 441urt that dy9aM1C respoatp l CharacterittlC1 Cf intbber tu* Meted Sy1tems and ComoMets will be bevaded within 4CCeDiable ll*lts. a et? s a C+- i SauSSe rs a re us ed w i d*1 v t % e eeu t the euelene industry at Seiteit g" " ". 26 LAi r yft e$c teRpaIra,Nt ekr*, Xwhff $
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Spoate: 2) deterwine 19 retMote tent 1tivity to variatices of thet* pa rsec t e rs. Based upen the results of the foregoing, tiglified dette and analy11'. procedures are proposed, to maintain tystee respoete with-6 in acceptable limits. I Ge m ac -*tutet e r i ten er~; i- . viluate tv e"ectseno6
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shall be increased by 100% for clearance h j f Deta nonlineer anal t s is recut red f or systews . n< okgreRer l c rance, j # i i { 2.2.3.4 a4thE1gry The guidelines for multiple sashber usage j are based on a single test prMras described in Referwece 1. I 2.2.3.4.1 A'NcNSM%i = y._--_.m-;ysimpic7a~rudIM1 y j 6 ,,,y g M MI M Mi TA M Y $ b"a"- ==ifdaf3 N )
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! The release rate is defined as the rate of snubber antal movement l under load af ter the snubber is activated. The release rate of the mechanical i snubber is ,the saee value as its activation level and independent of load.
The release rate of the hydraulic snubber is independent of its activation levet and is proportional to the applied load. The release rete of a hydraulic snubber is cexsoonly defined in terms of its t' iced rate and rated load capacity. The bleed rate is defined as the re l ea se ra te a t the s nubbe r ra t e d t r a d. Ibe bleed' rate of the hydraulic l snubber wied for corponent and piping systeas shall not onceed I g where. c!.Tf D 10M) IB * * (GAMI is7) inch / minute 4.. ' If the snubber is used to restrain piping, the cogonest weight represents the eculvalent piping weight. The equivalent weight is the weight loading at the snubber assuming all snubbers are locked with the gravity loadings acting in the direction of the snubber. 8.2.1. 3. 3 ,Cle a ra n c t The response of a pt;' $g systea or ccmonent sur ..-' d with snu' ers is highly dependent oa the clearaNes lecated at the bus . *ets. Tb s is especi ally t rue o f inca c t loa ts. [ralua tice of clearaev ' a SNc h 'c support locatio$ thall be based cm snubher free p'aj, end " tting clearances, pipe clarc tolersnces, and other clearances not indicated. The support clearance is thehu naticm of individual gaps esisting betwen 15e snubber backt.D support sthture and the center of gravity (or geo etry) cf the Component being supported. The total gap shall not esCeed .35 inch. rosas tow t any e.es
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August 10,1984 84042.014 . _ _ Mr. J. George Project Mcnoger Texas Utilities Genercting Compcny Highwcy FM 201 Cien Rose, Texcs 76043
Subject:
Force Distribution in Axial Restraints - Phase 3 Open item Comanche Peck Stecm Electric Station
, Independents Assessment Progrcm - Phese 3 Texas Utilities Genercting Company Job No. 84042
Reference:
Motion for Summcry Disocsition Regcrding Allegctions Concerning Considero-tion of Force Distribution in Axict Restreints, July 9,1934 Dect Mr. George: During the Phase 3 pipe support review Cygno rcised a question concerning the capropriate loading to be used in sizing stendcrd components (struts cnd snubbers) which cre used in pairs to form cxial restreints. The concern wcs not with the pipe stress cnclysis modeling techniques for this type of supoort, but rather with tne cppropricteness of sizing the struts or snubbers cssuming a 50% - 50% locd split. TUCCO responded by referring Cygno to the cbove referenced Motion for Summcry Disposition. Scsed on a review of that document, Cygno does not agree with the interpretation that the rotational constrcint provided by the double trunnion trc0eze supports constitutes a condition of restroint of free end dispiccement. And, therefore, en increcse in the ollowcble stress for these supports is not cppropriate. Justificction for the 50 6 iood split must be provided on en cppropricte bcsis. One such bcsis would be to demonstrcte that the support system provided sufficient ductility (deformction) to insure that the proper redistribution of forces occurs prior to cchieving ultimcte loed. Cygno understands that Dr. lotti hcs performed some studies on a pipe stress problem to determine whether the pipe cxial cnd rotational dispiccements cre coincident in time. Although we have not reviewed the results, Dr. lotti believes the correlction will be low. However, it may be dif ficult to justify the uncoupled nature of these dispiccements on a generic basis. Whi'e Cygna has noted that TUCCO bcs chosen a 50% - 50% lood solit for the design of the supports, the some is not true of the welded cticchment local stress evc!votion. In cll but one of the 16 double trunnion exici restrcints reveiwed during all four phcses of the Independent Assessment Progrom, the full lood (100%) was assumed for ecch trunnion san 8 aac sco Smo- Cmea;: A.:+aa:
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Uf$n Mr. J. George August 10,1984 ~ Page 2 - design. Although we thin'.< chec'c of cil double trunnions should be mcde to ensure en cppropriate lood split, it cppects this will not be o problem. Given this disegreement on the support design, however, Cygno believes that TUCCO must either evolucte the effects on the basis of support ductility or review the supports on a more specific bcsis without the increased alloweble before Cygno con close this item for 'he purposes of the Phase 3 reviews. If you prefer to hcve further technical discussions on this matter elecse notify me of this f ec t. Very truly yours, N. H. Williams Project N.anc;er cc: Mr. 5. Burwell (USNRC) Mr. 5. Treby (USNRC) Mrs. J. Ellis (C ASE) Mr. D. Wcde (TUCCO) Mr. G. Grcce 0 UGCO/ESASCO) Mr. D. Pigott (OH5) Mr. R. Sclierd (G&H)
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ENGINEER!NG GU10ELiNE TITLE ' CCVER SHEET 3 l3-i.?l; IOF 1 i AP* ROVE > SECTI0ti VI l GUIDELINE , ,. RICHMotiD IflSERTS & AfiCHOR REVISIONS
' I ,T e M-BOLTS STRESS ALLOWABLES g /r PSE PRCJ. ENGR.
I. INSTRUCTIONS FOR FILING GUICELINE PAGES Remove Section VI Rev. 2 and replace with Section VI Rev. 3. - Place this cover sheet in front of Section VI Rev. 3. le - 31*. STATUS dF GUIDELINE PAGES REVlPACI REV PAGE REVfPnGE REV PAGE REV PAGE REV PAGE l 1 1 l I I i g. l
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~ - Rev. 3 SECTION VI: RICHMOND INSERTS AND ANCHOR BOLTS STRESS ALLCWA3LES 1.0 REFERE"CES A. CP-EP-4.3 B. CP-EI-13.0-3 C. Letter GTN-57677 2.0 GENERAL This guideline is relative to the stress allowables for Richmond '
Inserts and the specific type of anchor bolts described. 3.0 RICHMONO INSERTS ALLOWABLE SINGLE ACTING LOADS Lead 1" 1h" Direction Insert Insert Tension 10.1 KIPS 25.0 KIPS Shear 9.5 KIPS 25.0 K!PS INTEPACT!GN REOUIREMENTS ( 7 \ A/3 . [y 4/3 .c f r (y t (v Where: T = Acoliec Tension V = Apolied Snear Ft= Allowable Tension Fy = Allowable Shear 3.1 ANCHOR BOLTS 3.1.1 GROUTED-IN ANCHOR BOLTS The following applies to a single 15" @ - AI93 belts installed in accordance with reference "Bd. : ALLOWABLE TENSILE CAPACITY Ultimate load condition - 105 KIPS Working load condition - 56 KIFS : ALLOWABLE SHEAR CAPACTTY I ' Ultimate load condition - 69 KIPS g- Working load condition - 34.5 KIPS , s. f
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,, ,,g[p U.S. NUCLEAR REGULATORY COMMISSION January 1978
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!. 4 REGULATORY GUlDE .
%,i OFFICE OF STANDARDS DEVELOPMENT REGULATORY GUIDE 1.124
, SERVICE LIMITS AND LOADING COMBINATIONS FOR CLASS 1 LINEAR-TYPE COMPONENT SUPPORTS A. INTRODUCTION with the specified seismic event. thus helping to General Design Criterion 2. " Design Bases for mitigate the consequences of system damage. Com-Protection Against Natural Phenomena." of Appen- ponent supports are deformation sensitive because dix A, " General Design Criteria for Nuclear Power large deformations in them may significantly change Plants." to 10 CFR Part 50 " Licensing of Produc. the stress distnbution in the support system ano its tion and Utilization Facilities." requiras that the de- supported components.
sign bases for structures, systems, and components In order to provide uniform requirements for con- . important to safety reflect appropriate combinations struction, the component supports should. .ts a of the effects of normal and accident conditions with minimum, have the same ASN1E Botier and Pressure - the effects of natural phenomena such as earthquakes. Vessel Code classification as that of :ne supporte.1 The failure of members designed to support safety- components. This guide delineates leveis of erme related components could jeopardize the ability of the limits and loading combinations, in addit:on to suppcrted component to perform its safety function. supplementary enteria, for ASSIE C' ass I !inearmpe This guide delineates acceptable levels of service component supports as defined by NF-1213 of See- . l limits and appropriate combinations of loadings tion III.as- Snubbers are not addressed in this guide. i sociated with normal operation, postulated accidents. Subsection NF and Aeoendix XVII of Section !!! and specified seismic events for the design of Class I permit the use of four metitods for the design of Class linear type component supports as defined in Subsec- I linear type component supports: linear elastic anal-tion NF of Section III .! the American Society of ysis, load rating. experimental stress analysis. and
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Niechanical Engineers (ASNIE) Boiler and Pressure 1 mit analysis. For each method. tne ASNIE Code de-Vessel Code. This guide applies to light water cooled lineates .illowable stress or loading limits for vanous l reactors. The Advisory Committee on Reactor Code le'.els of service limits as defined bv NF.3113 Safeguards has been consulted concerning this guide of Section III so that these limits can be used in con-and has concurred in the regulatory position. junction with the resultant loadings or stresses from the appropnate plant conditions. Since the Code does l B. DISCUSSION not specify loading combinations. guidance is re-Load beanng members classified as component quired to provice a consntent bas.s for the design of suppons are essential to me safety of nuclear power component supports. plants since they retain components in place during Component supports considered in this guide ar l the loadings associated with normal and upset plant located within Seismic Categorv i structures and are ' conditions under the stress of specified seismic ' therefore protected against lo'adings from natural events, thereby permitting system components to phenomena or man made hazards other than the spec. j function properly. They also prevent excessive com- f ed seismic events. Thus only the specified seismic l ponent movement during eventswithneed to be considered in combination with the emergency and faulted plant the loadings conditichs combined associated loadings associated with plant conditions to develop tai me cm sutmanuve chaap from prewma inue. appropnate loading combinations. Loadings eaused USNRC REGULA7OM GUlt'tS e.a=m *.* w~'.'*s av.e**c.**a auaa w. a ,,
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i s by datural phensmena other than seismic eve its, stresses should be calculated with the values cf E and when they exist, should be considered on a esse.by 6 S, of the component support matenal at temperature. . case basis. Allowable service limits for bolted connections are . denved from tensile and shear stress limits anf their
- 1. Design by Lineer Elastic Analysis nonlinear interaction: they also change with the size of the bolt. For this reason, the increases permitted
- a. 5. at Temperature. When the linear clasu.e by NF.3231.1 XVII-2110(sh and F-1370(a) of Sec.
- analysis method is used to design Class I linest type tion !!! are not directly applicable to allowable shear component suppotts, material properues are given by stresses and allowable stresses for bolts and bolted Tables I-2.1.1-2.2.1-13.1, and I-13.3 )n Appends' connecuons. The incrase permitted by NF-3231.1 '
I of Section III and Tables 3 and 4 in the latest ac- and F-1370 tap of Sci.uon !!! for shear stresses or cepted version' of Code Case 1644?These tables list shear stress range should not be mese than 1.5 times values for the minimum yield s:rength 5, at vanous the level A service limits' because of the potendal for temperatures but only room terr.perature values for non ducule behavior. the ulumate tensile strength S.. At reom temperature. S, vanes from 50% to 67% of S. for component sup. ' The rar:ge of primary plus secondary stresses port matenals. ,
' should be limited to 25, but not more than S. to en.
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- Levels of service limits denved from either mate- the value of 0.65 . the increase permitted by NF-nal property aWne may not be sufficient to proude a 32$1.lf at will be above the value of 25, and will consistent safety margin. This is recognized by Sec- thus violate the normal shakedown range. A uon !!!. since XVII-221!(a) of Secuan 111 defines . shakedown analysis is necessary to justify the the allowable stress in tension on a net secuen as the nerease of stress above 25, or S .
smaller value .of 0.65, and 0.55.. To alleviate thr lack of defir.ed values of S. at temperatures above For the linear elasue analysis method. F-1370(a) room temperature and to provide a safe design mar- of Secuen !!! permits increase of tension limits for gin an intenm method is given in this guide to obtain the Code level D service lirmts by a vanable factor values of S. at temperature, that is the smaller value of 1.25,.F or 0.75,,F .'De . pending n whether the section considered is s' net While XVil-2211(a) specifies allowable tensile section at pinholes in eyebars. pm connected plates. stress in terms of both 5, and S the rest of X\.ll- or built.up structural members. F, may assume the 2000 specifies other allowable service limits in tptms smaller value of 0.455, or 0.375S (as recommended of 5, only. This does not maintam a consistent design by this guide for a net secuon of pinholes, etc.) or the margin for these service limits related only to mate- smaller value of 0.65, oc 0.55. (for a net section rial properties. \. lodifications similar to XN !!- without pmholes. etc.L Thus greater values o(. the 2211(a) should be employed for all those service factor may be obtained for sections at pinholes, limits, which does not account for local stress and is not
- b. AltomabIt Increart of Semcc Limers. While consistent with NF-3231.1 did XVII-2110(a) of Sec.
NF 3231.lf a). XVII-2110(a), and F *370f ai of Sec. tion DL A procedure to conect this factor is provided tion 111 all permit the increase of allowable stresses in this guide. under vanous loading conditions. XVi!-2110ibe lim. its the increase so that two thirds of the entical buckl. 2. Design by Load Rating ing stress for compression and compression flange When load raung methods are used. Subsection NF members is not exceeded, and the increare allowed and Appendix F of Section !!!' do nor/ provide a by NF-3231.l(alis for stress range. Cnucal bucklin;; faulted condition load rs ing. This guide prov~ ides an stresses with normal desian margins are denved in intenm method for the determination of faulted con-XVil-2200 of Section III. Since buckling prevents dition load rating.
" shakedown" i ,n the load beanng member. XVil-2110(b) must be regarded as controlling. Also, buck!- 3. Design by Experimental Stress Analysis ing is the result of the interaction of the configuration of the load.beanng member and its matensi prop- While the collapse load for the experimental stress erties (i.e., elastic modulus E and mimmum yield analysis method is defined by !!-1430 in Appendix 11 strength S,). Because both of these matenal prcP of Secuen !!!. the vanous I vels of service limits for crues change with temperature, the entical buckling expenmental stress analysis are not delineated. This deficiency is remedied by the method desenbed in I
- Regulatory Gode I 13. " Code Case Acceptabihty-ASME Sec.
tion !!! Maisnals." provides godance for t.he acceptseihry of ASME 5ection 111 Code Cases and their revisions. inclacm3 Cxe 4. Large Deformation Case 194 Supple ne'stary provisions fer the use cf specific code cases and their revisions may also be prootded arid sPtould be con. The design of Compor.ent suppens is an integrai sidered when applicaele. part of the desig* of the system and its componems. Ikb 1.124 2 k f, ")
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A complete and consistent design is possible only lar plant condition, the stresses or loads resulting when systernscomponent/ component support interac- from the loading combinations under that plant condi-tion is properly considered. When all three are tion do not need to satisfy the design limits for the evaluated on an clastic basis, the interaction is usu- plant condition. ally valid because individual deformations are small. - However,if plastic analysis methods are employed in 7. Definitions the design process. large deformations that would re. Des:gn Condition. De loading condition defined sult in substantially different stress distnbutions may by NF-3112 of Section !!! of the ASME Boiler and Pressure Vessel Code. When component supports are designed for load. Emergency Plant Condition. nose operating con-ings associated with the faulted plant conditions. Ap- ditions that have a low probability of occurrence. pendix F of Section !!! permits the use of plasne analysis methods in certain acceptable combinations faulted Plant Condition. no>e operating condi-for all three elements. nese acceptable combinations tions associated with postulated events of extremely are selected on the assumption that component sup- low probability. ports are more deformation sensitive (i.e.. their de- erej, ot S evice Limits. Four levels. A. 9, C and formanon in general will have .: large ettect on the stress distnoutton in the spiem and its components.1 D. af ser'.Iiee limits defined bs Sect:en !!! fer the de-si n of loadings associated with different plant condi-Since large detormations always stfect the stress dis-tions for components and component supports in nu-tnbution. care should be excretsed even if the plastic dest power plants. analysis method is used in the Appendix F. approved methodology combination. This is especially impor- .vormal Plant Condition. Those operating condi-tant for identifying buckling or instability problems tions in the course of system stanup. opersuon, hot where the change of geometry should be taken into standby, refueling. and shutdown other than upset. secount to avoid erroneous results. emergency, or faulted plant conditions.
- 5. Function of Supported System Operating Basis Earthquake 10BE). As defined in Appendix A to 10 CFR Part 100.
In selecting the level of service limits for different . loading combinations, the function of the supoorted Plear Conditions. Operating conditions of the piant
, system must be taken into account. To ensua that categonzed as normal. upset, emergency. and tautted systems whose nonnal function is to prevent or miti- plant conditions.
( . gate consequences of events associated with an emer. Safe Shurdan Earthquake (SSE). As defined in gency or faulted plant condition (e.g., the function of Appendix A o 10 CFR Part 100. ECCS dunng faulted plant conditions will operate properly regardless of plant condition, the Code level Service Limars. Stress limits for the design of com-A or B service limits of Subsection NF (which are ponent supports as defined by Subsecuon NF of Sec. identical) or other justifiable lirnits provided by the tion III. l Code should be used. Specified Sersmic Events. Operating Basis Eartn. Since Appendix XVII derived all equations from quake and Safe Shutdown Earthquake. AISC rules and many AISC compression equations Svstem .tfechanical Loadings. The static and have built in constants based on mechamcal prop- dynamsc loadings that are developed by the system erties of steel at room temperature, to use these equa- o erating parameters. including deadweight. pres- I nons indiscriminately for all NF and the latest ac- sure, and other external loadings. but excluding er'- cepted version of Code Case 1644 materials at all fects resulting from constraints of free end move. l temperatures would not be prudent. For materials ments and thermal and peak stresses.
- other than steel and wo king temperatures substan-l tially different from room temperature, these equa- Ultrmarc Tensile Strength. Matenal property based i tions should be redenved with the appropnate mate- on engineering stress-strain relauonship.
rial properties. Upser Plant Conditions. Those deviations from the
- 6. Deformation Limits normal plant condition that have a high probab;lity of occurrence.
Since component supports are deformation-sensitive load bearing elements, satisfying the serv. C. REGULATORY POSITION ice limits of SectioriIll will not automatically ensure ASME Code' Class I linear-type component sup.
, their proper function. Deformation limits. if specified by the Code Design Specification, may be the con- . Amencan Society of Mechanical Engineers Botier and Premre trolling criteriori. On the other hand, if the funcuon vessel Code. Secuen tit. Dmsson 1.1974 Ednion, inctang ine [
- of a component support is not required for a partieu. 1976 Winter Addenda enereto- ;
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, s or the latest accepted version' of Code Case j pons exciuding snubbers, which are not addressed herein, should be constructed to the rules of Subsec- 1644. '
tion NF of Secuan !!! as supplemented by the follow-ing:
- c. Method J. When the values of allowable stress or stress intensity at temperature for a matenal
- 1. The classification of component supports are listed in Section Ill, the ultimate tensile strength should, as a minimum, be the same as that of the at temperature for that material may be approximated supponed components. by the following expressions:
- 2. Values of S, at a temperature t should be esti- 3, , 43 o, mated by one of the three following methods on an S= " 3S's -
interim basis until Section Ill includes such values:
*h*f'
- a. Method 1. This method applies to component S. = ultimate tensile strength at temperature t to suppon materials whose values of ultimate strength S, at remperature have been tabulated by their man- be used to determine the service limits ufacturers in catalogs or other publications. S. = listed value of allowable stress at temperature t in Section III.
S., = 5,,, S'1 S,. = listed value of allowable stress intensity at S , . but not greater than Sur temperature t in Secuon III where
- 3. The Code levels A and B service limits for com-S = ulumste tensile strengtn at temperature t to ponent supports designed by linear elastic analysis I be used to detennine the service limits which are related to 5, should meet the appropnate S , = ulumste tensile strength at room temperature stress limits of Appendix XVII or Secuon !!! but l
tat'ulated in Section !!!. Appendix I. or the should not exceed the limit grecified when the value l
.. tat accepted urvon' of Code Case 1644 of 5'6 3 2is subsututed ter a. c.xamples are shown j I
S ., = ultimate tensile strength at temperature t below in a and b. tabulated by manufacturers in their catalogs or other publications 2. The tensile strm limit F. for a net section as Si, = ultimate tensile strength at room temperature ,pe.nd in XV'l .2 ' & s4 Snt..in !!! should be tabulated by manufacturers in the same pub- the 3maller val.ie 4 0 nS or 0.55, at temperature. lications. _ For net sections at pinholes in e> e bars, pin-connected plates, or built.up structural members, F,
- b. #cthod 2. This method applies to component as speerfied m XVII-2211ab should be the smaller support matenals whose values of ultimate tensile value of 0.45S, or 0.3755. at temperature.
strength at temperature have not been tabulated by their manufacturers in any catalog or publication.
- b. Die shear stress limit F, for a gross section as S. specified in XVil-2212 of Section III should be the S. = Sur smaller value of 0.45, or 0.33S. at temperature. l 3,,
where Nianv limits and equations for compression S. = ult mate i tensile strength at temperature t i strengtti specified in Sections XVII-2214. XVII-be used to determine the service limits 2224. XVil-2225. XVil-2240, and XVII-2260 have [ S , = ultimate tensile strength at room temperature built-in constants based on Younis Modulus of tabulated in Secuon !!I. Appendix I. or the 29.000 Ksi. For matenals with You'ng's Modulus at latest accepted version' of Code Case 1644 working temperatures substantially different from 29.000 Ksi, these censtantn should be redenved with S, = minimum yield strength at temperature t tabulated in Section 111. Appendix 1. or the the appropriate Young's Modulus unless the conser-latest accepted version' of Code Case'1644 vatism of using these constants as specified can be demonstrated. S,, = minimum yield strength at room temper-I ature, tabulated in Section III. Appendix I.
- 4. Component suppens designed by linear elastte analysis mav increase their level A or B service limits s If the function of a component support is not required dunng a according to the provisions of NF-3231.l(at. XVII-P3*"' '*"d"' " 'h' dtn timits of the suppon for that plant con. 2110(a), and F-1370(a) of Section III The increase
' of levei A or B service limits provided by NF-
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3231.!(a) is for stress range. The increase of level A other safety.related systern 1.124 4 .
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Secuon III divided by 1.7 should not be exceeded for
, or B service limits provided by F-1370(a) for level D service limits should be the smaller factor of 2 or component supports designed by the experimental 1.167SJSr. if Su a 1.25, or 1.4 if Su is 1.2S,. stress analysis method.
where S, and Su are component support material
- 6. Component supports subjected to the system Properties at temperature. mechanical loadings associated with the emergency However, all increases (i.e.. those allowed by plant condition should be designed within the follow-NF-3231. l(a). XVil-2110(a). and F-1370(a)] ing design limits except when the normal function of should always be limited by XVII-2110(b) of Section the supported system is to prevent or mitigate the III. The critical buckling strengths defined by consequences of events associated with the emer-XVII-2110(b) of Section 111 should be' calculated gency plant condition (at which time Regulatory using material properties at temperature. This in. Position 8 applies):* 8 level A r B service limits does not apply t a. The stress limits of XVII-2000 of Section III
".rease limits for bolted connections. Any increase of limits and Regulatory Positions 3 and 4. . increased accord-for shear stresses above 1.5 times the Code level A ,
ing t the pr visions of XV11-2110(a) of Section III service limits should be justified. and Regulatory Position 4 of this guide, should not If the increased service limit for stress range by be exceeded for component supports designed by the NF-3231.l(a) is more than 25, or S , it should be linear elastic analysis method. limited to the smaller value of 25, or Su unless it can b. The emergency condition load rating of NF-be justified by a shakedown analysis. 3262.3 of Section ill should not be exceeded for
- 5. Component supports subjected to the combined component supports designed by the load-rating loadings of system mechanical loadings associated method.
with II) either (at the Code design cor*daion or (b) ,.
- c. .s..e ! wer bound collapse load determined by the normal or upset plant conditions anu : 2) the vib-ratory motion of the OBE should be eyned within ', .'.'11 4110t al,. !400 f Seen adjusted n ill according sh uld not to the provis be exceeded
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the following limits: ..s ter component suppons designed by the limit analysis
- a. The stress limits of XVII-2000 of Section ill method.
and R.gulatory Position 3 of this guide should not be W di e d M00 e' exceeded for component supports designed by the Section 111 divided by 1.3 should not be exceeded for linear elastic analysis method. These stress limits component supports designed by the expenmental may be increased according to the provisions of '"'" ""*D *' ' * * *h d ' NF-3231.l(a) of Section 01 and Regulatory Position _ 4 of this guide when effects result:ng from constra.nts 7. Component supports subjected ta the combinec of free.end displacements are added to the loading loadings of (1) the system mechanical loadings as- ! combination. sociated with the normal plant condition. (2) the vib-ratory motion of the SSE. and (3) the dynamic system ,
- b. The normal condition load rating or the upset I adings ass ciated with the faulted plant condinon i condition load ratine of NF-3262.3 of Secuon !!! should be designed within the following limits except i should not be exceeded for component supports de- when the normal function of the supported system is signed by the load rating method. to prevent or mitigate the consequences of events as- j
- c. De lower bound enilapse load determined by sociated with the faulted plant condinon (at which g I
XVII-4200 adjusted according to the provision of time Regulatory Position 8 appliest XVil--8110(a) of Section III should not be exceeded a. The stress limits of XVil-2000 of Section !!! for component supports designed by the limit analysis and Regulatory Position 3 of this guide, increased ac-cording to the provisions of F-1370(a) of Secuan !!!
- d. The collapse load determined by 11-1400 of and Regulatory Position 4 of this guide, should not be exceeded for component supports designed by the linear clastic analysis method.
- Since component supports are deformation sensitne in the performance of their service tsquirements satisfying these entena b. The smaller value of T.L. x 25/Su or T.L. x does not ensure that their functional requirements will be fulfilled.
0.75?Su should not be exceeded, where T.L., S. anc Any deformation limsts specified by the design specification may be controlling and should be sausfied. S., are defined according to NF-3262.1 of Secuan III. and S'u is the minimum ultimate tensile strength
' Since the deusa of component supports is an inregral part of the of the material at service temperature for component deugn of the system and the design of the component, the de- supports designed by the load. rating method.
ugner must make sure that methods used for the analysis of the system. component. and component support are compauble (see c. De lower bound collapse load determined by - Table F-13....-l in Appendia F of Section III) t.arge deforma. XVil--1200 adjusted according to the provision of noas in ihe sysiem or components shouid be considered in the Jesign of component supports. F-1370(b) of Secuan III should not be exceeded for 1.124-5 f ,} } 2
- 7. - .
^^
component supports designed by the limit analysis D. IMPLEMENTATION method.
- d. The collapse load determined by 11-1400 ad-justed according to the provision of F-1370(b) of "Ile purpose of this section is to provide guidance Section III should not be exceeded for component to applicants and licensees regarding the NRC staff *s suppens designed by the experimental stress analysis Pl ans for using this regulatory guide. -
method.
- 8. Component supports in systems whose normal Except in those cases in which the applicant pro-function is to prevent or mitigate the consequences of poses an acceptable alternative method for complying events associated with an emergency or faulted plant with the specified portions of the Commission's regu-condition should be designed within the limits de- lations, the method described herein will be used in senbed in Regulatory Positiori 5 or other justifiable the evaluation of submittals for construction permit limits provided by the Code. These limits should be applications docketed after January 10.1978. If an defined by the Design Specification and stated in the applicant wishes to use this regulatory guide in de-PSAR. such that the function of the supported system veloping submittals for construction permit applica-will be maintained when they are subjected to the tions docketed on or before January 10.1978. the loadi ; ombinations described in Re;;ulatory pertinent portions of the application will be evaluated Posit: ens 6 and 7. on the basis of this guide.
{ l 1 13 ri l
{O* N Y 849416
%, n.z""* h}e77 %;tIV N 'V p ,**
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION . BEFORE THE ATO'ilC SAFETY AND LICENSING BCARD In the Matter of i i TEXAS UTILITIES GENERATING l Occket Nos. 50-445-1 COMPANY, et al. l and 50-446-1 i (Comanche Peak Steam Electric Station i Station, Units 1 and 2) 1 CASE'S PARTIAL ANSWER TO APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE REGARDING SAFETY FACTORS in the form of Affidavit of CASE Witnesse rk Walsh and Jack Dovl L J MESSRS. WALSH AND DOYLE: Before addressing Applicants' statements in detail, it should be noted that it is our belief that Applicants' Motion for Summary Disposition is a deliberate attempt to mislead the Board. CASE was talkirg about apples; Applicants in effect have said that they don't want to talk about apples, but they have some oranges they'd like to sell to the Board. CASE should probably move that Applicants' Motion be stricken. Having said that, however, we also believe that at least a brief Answer is called for to give the Board a small sample cf the manner in which Applicants are trying to mislead the Board. Further, we are not ready to allow Applicants' Motion to stand in the record unchallenged, since their statements give the erroneous impression that it doesn't really matter if things are wrong here and there, since they supposedly have this large margin of safety on the order of 45. {if0 3
- 1. Applicants state:
" Seismic loading is the design determining force for virtually all piping supports of concern at CPSES. Affidavit of J. C. Finneran, R.
C. Iotti and R. D. Wheaton Regarding Safety Factors (' Af fidavit') at 3." In regards to Applicants' statement, first of all, there is no indication that R. D. Wheaton or R. C. Iotti are really familiar with pipe supports at Comanche Peak; for instance, it is not shown on their resumes that they have ever designed a pipe support at Comanche Peak Sl. In addition, we do not agree with Applicants' statement. As was shown in CASE's response to Applicants' Motion for Summary Disposition Regarding the Effects of Caps on Structural Behavior Under Seismic Loading Conditions, the support configurations are unique to Comanche Peak (i.e., Richmond Insert /A307 bolt / tube steel connection). Applicants cannot make a valid comparison based on past histories of other plants where this unique support configuration is not used. The Applicants are neglecting to consider the consecuences of normal operation at Comanche Peak in their discussion of safety factors (as discussed at the bottom of page 3 of Applicants' Affidavit). When one neglects the normal operating loads and stresses, one cannot be assured that the structural system will be operating in a predictable manner for a dynamic event. 11/ We also note that Mr. Wheaton's resume includes, under " Selected Publications" on page 3, two publications in June 1984 and one in 1985 which apparently have not yet been commented on by his peers. In addition, we note that not included in Mr. Wheaton's resume is (from all appearances) that he helped prepare Reference 4 (see the
- discussion under answer 4, item (1.), later in this Answer). 1 See also Pages 1 and 2 of Affidavit.
2
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- 2. Applicants state:
"A conservatively quantified margin of safety associated with some f actors affecting seismic design is on the order of 46 (Id,. at Table 2,
- p. 43) and consists of the following items:
"a. Seismic Hazard Evaluation - 2.4 (Id. at 9-10)
"b. Composite Ground Motion - 1.5 (Id at 10-11)
"c. Synthetic Time-History - 1.2 (Id,. at 11-12)
"d. Site-Structure Interaction Analysis - 1.5 (Id. at 18-21)
"e. Damping - 1.38 (Id_. at 22-25)
"f. Uncoupled Analysis - 1.1 (Id,. at 25-26)
"g. Envelope Support Excitation Approach - 1.1 (Id,. at 27-28)
"h. Broadened Floor Response Spectra - 1.1 (Id 28-29)
"1. Orthogonal Input Motions - 1.1 (Id,. at 29-30)
"j. Modal Combintion Rules 2 (Id,. at 30-32)
"k. Material Overstrength - 1.8 ( H. at 35-36)
"1. Static Reserve Strength (Code Margin) - 1.43 to 10.41 (assume 1.43 for calculation) (Id. at 36)
"m. Dynamic Reserve Strength - 1.5'(Id,at 37)"
We disagree with this statement, which is very misleading. The Applicants (beginning on page 2, laat paragraph and continuing onto page 3 of the Affidavit), attempt to explain how a safety factor is born. As will be shown in the following, the factors listed above are not applicable to the design of pipe supports at Comanche Peak, since they are related to Seismic B load factors and not caoacity factors as required in the working stress design, which CASE referenced in their Proposed Findings. (See CASE's Proposed Findings of Fact and 3
Conclusions of Law (Walsh/Doyle Allegations), pages I - 6 through I -
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10.) In none of their discussions do they discuss the real world which is controlled and accepted by recognized codes, standards, and NRC Regulations to which Aeolicants are committed. In CASE's Proposed Findings, CASE argued that the factor of safety against the allowable stress was being eroded. The loads that produced the stresses were not argued by CASE 1 its Proposed findings except when it was totally neglected. There were many points which CASE simply did not get into, regarding which we accepted Applicants' word. For instance: CASE did not a gue that the temperature within the containment should be 600 degrees F. during a LOCA (which might be argued due to the temperature of.the main steam line) instead of the 280 degrees F. which Applicants use. CASE did not argue that the response spectra method was unconservative. CASE did not argue that the recuired damping factors which the Applicants are committed to use was too liberal. What CASE has argued in the past is that the safety factor has
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been eroded due to the following (just to name a few): (1) Section properties not properly considered; (2) Oversize holes and gaps not considered; (3) Self-weight excitation of supports not being considered; (4) Not considering the consequences of wall-to-wall and floor-to-celling supports; (5) Not considering friction loads; 4
(6) The restraining effects from trunnions not being considered; (7) Lack of consideration of local stresses; (8) Unstable supports; (9) Applicants' misuse of Code cases, as with Code Case N-71-10 in regards to A500 steel; etc. If the Applicants are so confident that they have a factor of safety equal to or greater than 46, why don't they decrease their load by 46 times and move on? Then instead of using a , load factor of 1.7, they could have used a load factor of 1 + 1/46 = 1.02. The reason is that it is not realistic and the Applicants know it. Further, there is no indication that the NRC Staff has approved Applicants' premise. Utilizing the Applicants' philosophy and realizing a load factor of 1.02, what the Applicants are in essence saying is that they do not need to consider seismic or dynamic events because there is only a 2% increase in load due to seismic or dynamic events. The factor of safety of 46 is assuming a Utopia where nothing goes wrong and everything has been done correctly. (For instance, Utopia would include the following: no cinched-down U-bolts, all friction connections rather than having bearing connections, stable supports, etc.) This is unrealistic and is far from the situation at Comanche Peak. Applicants are not discussing factors of safety for design -- they are actually discussing factors of safety for loads. See Applicants' Affidavit at page 3, where they state: 5
"If the one category just mentioned (including code margins raised a by CASE) is termed ' capacity' safety factors, then the other two categories may be called ' design input definition' and ' method of analyses' caused safety factors."
CASE has discussed apples -- but the Applicants are discussing oranges. As stated before, the Applicants are only considering the seismic or dynamic factors oi safety. Two accidents that did not involve seismic or dynamic events that are recalled very quickly are TMI and the Kansas City walkway collapse. The TMI accident was an accident under normal operating conditions and no dynamic events were involved, as was the case with the pipe support in CASE Exhibit 669B, 11XX. The Kansas City accident involved a structural shape in the form of tube steel, where a threaded rod punctured through the bearing surface, and this was done because of a field change. It will be noted that all these chsnges were either done verbally or by memo. This is still being litigated. (See Attachment A hereto, from Engineering News Record.)
- 3. Applicants state:
" Additional design margins of safety which exist and add an additional level of margin, but were not quantified and set forth in 4 above, include the following:
"a. Enveloping of SSI Results (Id. at 21-22) .
"b. Inelastic Deamplification (Id,. at 32-34)
"c. Oversized Members ( H. at 37-38)
. "d. Redundancy (Id. at 4-5)" See answer 2 preceding. In addition, throughout their Affidavit, 6 i _
Applicants refer to most of the 44 References listed in Attachment 3 to their Affidavit. CASE has now received all but one of the items (No.
- 37) referenced in Attachment 3. However, we have not had time to thoroughly review the 44 referenced documents /2/.
. - s.
, MR. WALSH:
~~
L-~s One of the most striking aspects of those References in Attachment 3 which I have had time to quickly scan is what Applicants are not_ telling the Board is stated in those documents. For example, it is obvious that those References are relying upon certain very important criteria having been met before the other assumptions can even begin to be adequately evaluated: (1) ". . . Rigorous nonlinear dyanmic analysis methods are valuable tools in seismic analysis and design when combined with engineering judgement, careful detailing, and cuality construction workmanship. . . (Reference 31 (referenced on page 38 of Applicants' Affidavit: "Non-Linear Structural Dynamic Analysis Procedures for Category I Structures," prepared for USNRC by URS/ John Blume and Associates, San Francisco, CA, July 1978.) (2) I have briefly scanned portions of Reference 4. This draft report (American Society of Civil Engineers, " Uncertainty and Conservatism in the Seismic Analysis and Design of Nuclear Facilities," ASCE Dynamic Analysis Committee, Working Group Report, 1983 (Draft)), which Applicants' Witness Mr. Wheaton f2/ Applicants supplied CASE with only one copy of each of these 44 documents, and ({c. Doyle}has net seen any of these documents.
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7 T
.E. _
apparently helped prepare, was referenced in Applicants' Affidavit on pages 6 and 10. (This was one of the more recent References which was included in Applicants' list.) It states, in part:
"In addition to the parameters discussed in this report, three other considerations that affect the failure / survival characteristics of structures and subsystems are design and construction errors, aging, and construction oractices.
Design and construction errors are particularlv troublesomaj They introduce additional uncertainty as to the capacity of a constructed facility. It is improper to accept errors as the status quo, to uniformly increase the uncertainty assigned to the analysis parameters, or to compensate for errors through inflated safety factors or margins. The proper solution is to practice good quality assurance / control techniques to eliminate or effectively minimize the possibility for errors." (Page 1-8, emphases added.) (3) Another important document referenced by Applicants (page 24 of Affidavit) is Reference 16, KUREG/CR-0098, September 1977,
" Development of Criteria for Seismic Review of Selected Nuclear Power Plants," by N. M. Newmark and W. J. Hall. This is one of the more important documents referenced by Applicants because, although it does not have the force of NRC regulations or carry as much weight as Regulatory Guides, it does indicate that the NRC itself has taken a detailed look at this specific matter. It therefore is entitled to that amount of weight by the Board. It states, in part:
"In order to survive the dynamic motions, the element must be strong enough as well as ductile enough to resist the forces and deformations imposed on it. The required strength and ductility are functions of stiffness or flexibility, among other things. In assessing seismic effects it should be remembered that the seismic actions generally are in addition to those already existing, i.e., arieine from dead load, live load, thermal effects, etc." (Page 3 of Report, emphasis added.)
8
"The process of earthquake resistant review and design requires selection of earthquake hazards as well as estimates of structural strengths, either implicitly or explicitly, as an integral part of the review procedure. Unless these determinations are made in a consistent manner, the final design may be either grossly uneconomical or dangerousiv unsafe." (Page 5, emphases added.)
"Obviously approoriate damoine values also must be chosen for use in evaluating the seismic adequacy of the systems under study." (Page 28, emphasis added.)
" Items which do not lend themselves readily to analytical consideration may have an imoortant effect on the response of structures and facilities to earthquake motions and must be considered in the design. Among these items are such matters as the details and material procerties of the elements and components, and the inspection and control of ouality in the construction procedure. The details of connections of the structure to its support or foundations, as well as of the various elements or items within the structure or component, are of major importance. Failures often occur at connections and joints because of inadecuacy of these to carry the forces to which thev are subjected under dynamic conditions. Inadequacies in properties of material can often be encountered, leading to brittle fracture where sufficient energy cannot_be absorbed, engouth though energy absorption may have been counted on in the design and may be available under static loading conditions. . .
"The review must include examination of details of construction, fastening, and actual material crecerties tc be sure that the resistance available is adequate to meet the deannds of the upgrded design requirements." (Pagt 38, emphases added.)
l Obviously CASE's concerns about Applicants' inflated safety factors are in strong controversy and go to the very heart of CASE's Answer to this Motion for Summary Disposition, since safety factors will be eroded by design and construction errors, poor construction practices, ignoring consideration of items which should be properly 9 w * -
considered, lack of consistency, use of improper values, intimidation of QC inspectors, inadequate OA/CC techniques and effectiveness, etc., etc. Applicants have done the very things which Reference 4
-- the ASCE Report which Applicants themselves referenced and which it appears one of their witnesses helped prepare --
warns against, and Applicants are now attempting to convince the Board that safety factors exist which are in actuality inflated. Throughout Applicants' Af fidavit, there are numerous references to
" current nuclear industry practice," " current engineering practice,"
" current practice," and " industry practice." (Pages 6, 8, 9, 10, 22, 24, 28, 30, and 42, for example.) And on pages 5 and 6 of Applicants' Affidavit, it is stated:
"The performance of structures and components during past earthquakes indicates that the average facility has a seismic i capacity well in excess of its design value. This is true even in j those cases, such as petro-chemical plants, where only minimal j attention was originally paid to seismic issues. In the case of l nuclear power plants, seismic reserve margins would be even
- greater than for the average facility. (Reference 1 through 4).
In short, current nuclear industry practice leads to both a significant overestimate of seismic forces and an underestimation l of seismic capacity. The result is a seismic reserve margin, or l added safety factor, that far exceeds original design targets." ! (Emphasis added.) And on page 9 of their Affidavit, Applicants state: l " Time intervals of such a magnitude are approaching a geologic I time scale and are probably physically unrealistic for engineering purposes. Nonetheless, current nuclear industrv practice results in a seismic ground motion that is 'at least a factor of 2.4' l times the design objective (Reference 4) (underline included in l reference)." (Additional emphasis added.) l 10 1
~
r s
In briefly scanning the same Reference 4 (the 1983 ASCE Report) discussed in the preceding on page 7, I found the following statements:
" Currently in the nuclear industry, probabilistic risk assessments (PRAs) are being conducted to quantify the probability of various adverse consequences which could occur in the event of a serious accident. . ." (Page 1-4, emphasis added.)
It should be noted that this current nuclear industry practice recently the untempered reliance by the nuclear industry on probabilitic risk assessments (FRA's) -- which is included in current nuclear industry practice -- has come under fire. In a March 11, 1983, Memo from M. Bender, NRC Advisory Committee on Reactor Safeguards (ACRS), Washington, to D. Okrent and ACRS
~
Members /4/, there was a discussion regarding the examination of accident precursors, and the following statements were made regarding probabilistic risk assessments (PRA's):
"Most of the effort has been directed to the implications of accident precursors in probabilistic risk assessment. The results of the Oak Ridge-SAI work and the INPO review of the Oak Ridge effort show clearly why PRAs are not good measures of safety adecuacy. So much subjective judgment is involved in the probability evaluation that the results cannot be trusted for absolute risk measurement. . ." (Emphases added.)
Another example of what Applicants are not telling the Board is that virtusily all of the referenced documents (at least all which I had time to quickly scan) had one thing in common -- uncertainty. This uncertainty raises strong questions about statements such as the following one from page 5 of Applicants' Affidavit: ff4/ See Attachment S hereto. 11
i N 4
". . . one study (Reference 36) has shown that, not only is there a large seismic reserve margin in the average piping system, but that it is virtually impossible to actually fail a pipe through seismic excitation . . ."
However, this 1983 report f 5/ also discusses some of the uncertainties involved:
". . . based on the data regarding the controlling failure mode of fatigue, it may be difficult to establish generic reserve margin factors applicable to all piping systems.
Also, local ductility cemands vary considerably from system to system for complex piping configurations, leading to difficulties in defining generic reserve margin factocs based on allowable system ductilities. . ." (Page 6-2.)
". . . the precise f ailure levels and modes have not yet been established, primarily due to a lack of available experimental data. Therefore, the most important challenge in the follow-on work is to identify precise failure modes and corresponding failure load levels for piping system and components. Once these are established, the development and justification of modifications to the ASME Code criteria will be relatively straightforward." (Page 7-1, emphasis added.)
Additional random selections from the References include the following clear indicators of uncertainties about which Applicants have conveniently forgotten to inform the Board: (1) ". . . it is difficult to predict the outcome of an innovative program that is still in progress . . . .
. . . the innovative nature of the Site Specific Spectra Program and the need for continued review and maturation of the program. . . .
l
. . . follow up work and sensitivity studies are continuing l
f5/ Reference 36: " Conceptual Task to Develop Revised Dynamic Code Criteria for Piping," R. Broman, et. al., Impell Corporation Report, Prepared for Electric Power Research Institute under Project RP-1543, 1983. 12 l
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=
(Reference 5 referenced on page 9 of Applicants' Affidavit: From 6/23/80 cover memorandum from Robert E. Jackson, Chief, Geosciences Branch, Division of Engineering, NRC, Washington, to D. Crutchfield, Acting Chief, Systematic Evaluation Program Branch, attached to Applicant s ' Reference 5. U. S. Nuclear Regulatoy Commission, " Initial Review and Recommendations for Site Specific Spectra at SEP Sites.") (2) ". . . The Pressure Vessel Research Committe, through our Steering Ccamittee and Technical Committee on Piping Systems, are develoning an overall position impacting on the design and support of piping systems under dynamic loads with emphasis on seismic. .. (Emphasis added.) (Reference 22, unable to find reference in Applicants' Affidavit unless I overlooked it: 6/9/83 cover letter fres L. J. Chockie, Chairman, Pressure Vessel Research Committee of the Welding Research Council, to W. R. Mikesell, Pressure vessel Committee, American Society of Mechanical Engineers, attached to Reference 22, PVRC, " Proposed Provisions to ASMI
' Appendix N and Reg. Guide 1 122" Task Group Report on Spectra Development , 1983.)
(3) ". . . Various aspects of this study, including the structures considered, the analysis criteria, the dynamic loadings, and the material properties, are purely hypothetical. These aspects are interded to model Category I conditions, and any resemblance to specific nuclear power plant structures is purely coincidental." (Page 1 of Report.)
"It is always difficult to model reinforced concrete members properly because reinforced concrete is a composite material exhibiting tensile cracking at low stress levels, bond-slip between the concrete and steel reinforcement, aggregate interlock, degrading stiffness, and spalling under cyclic loading. . . Many uncertainties would still remain even if more refined mechanical models were formulated because of variations in material procerties. . . Until such capabilities are developed, crack propagation, spread of plasticity, concrete spalling, and crushing cannot be examined properly. . .
" Additional work is needed to catalog experimental data relevant to nuclear power plant structures and to perform further tests to accumulate enough data so that accurate mathematical models encompassing the key parameters may be developed and used. . .
13 e- - -
-n-- - ,,
"The response of a structural system after the formation of a collapse mechanism is extremely sensitive to the time -
variations of inertia forces. ..
". . . it is difficult to specify a confidence level for nonlinear responses of the structures as computed by the rigorous methods. . .
"In the second phase . . . This will require a major software development effort . . .
"In the third phase . . . (t)he problems are twofold. First, no comprehensive constitutive model of concrete under triaxial cyclic loading is currently available. Secondly, the cost of a total three-dimensional analysis may be prohibitative at this point. ..
"Among the three phases discussed above, the first two may yield uncertain results. . . The third phase seems to be the most straightforward . . .
"Various trends indicate that the future course of structural engineering vill require more explicit considerations of the nonlinear, inelastic strength and energy capacity of structures. . . Development of such an analysis method would be a considerable undertaking; however, it is clearly needed for a more complete yet practical accounting of the nonlinear strength of structures," etc., etc. (Emphases added.)
(Reference 31, referenced on page 38 and Attachment 2 of Applicants' Affidavit: "Non-Linear Structural Dynamic Analysis Procedures for Category I Structures," prepared for USNRC by URS/ John Blume and Associates, San Francisco, CA, July 1978.) Thus, as demonstrated by a random sampling of Applicants' own referenced documents, the conclusions drawn by Applicants are not based on proven technology or analyses. Further, Applicants' own documents include staterents which support and reinforce CASE's positions. If these seismic design margins (referenced in Applicants' alleged material fact 4) are significant, then the safety factors incorporated , 14 i
in the codes (i.e., through allowable stress margins, or required load inputs) will have been reduced and Comanche Peak would have utilized them and they would have been included in their FSAR -- but they were not. Since this has not been done, the Applicants' statement is immaterial. Further, in their Affidavit, Applicants have failed to include the fact that their premise is based on certain additional considerations, and that if these additional considerations are not included, their premise is not valid. For example, included in some of the recent information received from Cygna was a Julv 4, 1984 TUCCO Office Memorandum to G. Grace from G. M. Chamberlain (see Attachment C hereto). As stated in that memorandum, the safety factor has been reduced:
"*In this case a 30% overstress of the bolt does not mean failure but only a reduced factor of safety. . ."
Since there was apparently no NCR, CMC, IR, or other nonconformance documentation on this problem, there is no way of knowing how many other similar instances of a reduced safety factor there have been at Comanche Peak, or how much the combination of those instances have reduced the overall safety factor. Additionally, the Applicants currently utilize a refined response spectra curve, as shown in the July 4, 1984 TUGC0 Office Memorandum to G. Grace from C. Ray (see Attachment D hereto), which states, in part:
"These loads can be shown in the analysis AB-1-23B Rev. I analyzed incorporating refined resonse spectra, refined seismic anchor movement and modified coding of the valve stem in consistence with 1-23A, C, and D.
15 6
,e=
d The Applicants, in theLr Affidavit at page 33, claim that they have a higher factor of safety due to inelastic deamplification, and they refer to Raference 32 to support that statement. However, according to Reference 32 /6/, the refined response spectra cannot be , used when using this technique for deamplification. It is stated on page 6 of that document:
". . . elastic spectra, rather than reduced spectra, should be
~
used for seismic input."
- 4. Applicants state:
" Numerous studies of the effects of seismic events on major structures support the conclusion that seismic design margins are significant,
- d. at Attachment 2."
Applicants' state on page 5 of tb.eir Affidavit:
". . . This is borne out by cheervations conducted at several plants subjected to severe earthquakes. It is to be noted that these plants were not built with the stringent QA requirements applied to nuclear plants. A summary of these observations is provided in Attachment 1 (sic -- shculd be Attachment 2).."
It should be noted that throughout their Affidavit, Applicants de not indicate the page numbers from which their statements are taken, nor did they attach copies of any of the pages. This tends to give the erroneous impression that the entire document supports Appliaants' position, which is not correct.
/6/ Rsferred to on page 34 of Applicants' Affidavit: " Seismic Analysis Methods for the Systematic Evaluation Pesgr.aq," UCRL-52528, Lc9eence Liversere Laboratory, Livermore, California, J.uly,1978, by T. A.
Nelson. 16 N
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O Attachment 2 to Applicants' Affidavit statest ". . . $everal examples of these events are discussed in References 37 through 41." To the best of my knowledge, CASE has not yet received Reference 37; we have receitad the rest, however. In -their discussion of References 37 through 41, there are cer: sin things which the . Applicants failed to state. F6: example: Reference 33 (El Centro Steam Plant, discussed en pages 1 and 2 of Attachment 2 to Applicants' Affidavit)r It was concluded that highly damped soil springs reasonably reflect the forces induced on the building (page xvi). Comanche Peak does not have the same characteelstics of sub-surf ace as the El Centro plant, and therefore a comparison is not truly appropriate, and any comparison would be unconservative. In addition, this report concludes , that only nuclear power plant equipment similar to that in Unit 4 and , anchered as well should perform equally well in a similar earthquake. (Page xvi). Since Comanche Peak has been known for its unique design . (i.e. , cinched-up U-bolts to provide stability, Richmond insert / tube steel idea, as well as others), this is another reason not to cespare . Comanchs Peak sich this report, and to do so would be unconservative. One further note is that damage was done to the piping system during i-thic earthquake (p,sge 1); that is, the cooling water piping line was damaged, the water treatment line and the hydrogen cooling water line were damaged (page 9). In addition, many mechanical equipment supports were damaged; for example, air-actuated valve operators, heat l 17 3
1 k
. l exchangers, and horizcntal tanks. The feedwater supports were replaced with new designs due to plastic deformations. (Page 10.) Unit 4 was out of service for two hours, so that plant personnel could inspect the damage. Unit 3 was restored to service within 15 minutes af ter the main shock. Only by expedient plugging of leaks was Unit 3 kept in service. Although Unit 4 was back in service within two hours. it was taken out of service within three hours to make the repairs. (Page 1.)
One must remember that this was not a nuclear power plant and all the repairs could be made without any risk due to radioactivity. Reference 39 (discussed on pages 2 and 3 of Attachment 2 to Applicants' Affidavit): Thls is a very brief report by Westinghouse regarding the Diablo Canyon plant which is based on the information about the El Centro plant (which is discussed in detail in Reference 38). Reference 40 (discussed on pcge 3 of Attachment 2 to Applicants' Affidaivt): This report states that in the mill buildings, designed for about 0.15g with x-bracing, there was a substantial amount of f ailed x-bracing, usually at the bolted connections, and there was also sone bending and stretching of some anchor bolts. The plant had toppled bins and conveyots, twisted crane rails, cracked walls, cracked valves, displaced pipelines and supports, broken steam and water mains, dislodged equipm;nt, etc. The reason for these damaged plant items was , inadequate seismic considerations. As pointed out in the report, comparisons were difficult. This plant was out of normal operation for 18 m
6 days. (Page D35.2.) It must be remembered that this was not a nuclear power plant where radioactivity could have jeopardized the repairs and the public health and safety. Reference 41. Unless I have overlooked it, this does not appear to be addressed at all in Attachment 2 to Applicants' Affidavit. This was a vety short paper presented in 1980 on " Seismic Perferpance of Piping in Past Earthquakes." It briefly d!.scusses several earthquakes, which (from a brief scanning) appear to have ranged from a 60 MW to 600 MW plant. None of the plants were nuclear power plants. There is another, even more disturbing, aspect of this to which we would like to call the Board's attention. In their statement on page 5 cf their Affidavit (discussed in the preceding), Applicants refer to the " stringent QA requirements applied to nuclear plants'? as though those requirements were actually being met at Comanche Peak. As the Board is aware, this is one of the steam of contention in these proceedings, and we challenge this implication.
- 5. Applicants state:
" Loads from sources other than a selsnic event (i.e. , sta'ic t and other dynamic loads) are generally well known, and in many instances the impacts of such loads are tested, e.g., hydrostatic tests, hot functional tests, and operational tests. See e.g. , Chapter XIV of the FSAR for a list of tests that have been and will be conducted. -Id at 3-4."
'9
, M
I strongly disagree with A;plicants' representations, jee, disc 4ssian on paga.s 16,17, and 18 of CASE's B/23/84 Parttai Ansuer to f Applicants' Statement of Esterial Facts As To Whien there Is No Genuine Issue RegArding Applicants' Use of Generic Stif fnesses Ins'etad of Actual Stiffnesses in Piping Analysis. See also CASE's 10/13/83 (1) Motion to Add A Mew Contentions (2) Motio.n for Discovsry, and (3) Offar i of Proof.
- 6. Applicants state:
"Many safety margins which apply to seismic desien apply equally well to static and other dynamic loads. M. "
As shown in the documents referenced in answer 3 abov.e. the factor of safety or the Applicants' ability to predict the tahavi6r of a piping system fer a hydrostatic and hot functional rest is less than what normally would be desired. Equsily icportant le the poor showing . of the predictabilitf of the Hot Tucctional Test (HFT), and the Applicants are rerunning some of the tests. The Staff will not be able to tell the Applicants to perform a seismic test, which is one test which the Applicants cannot and will not perform -- yet it is the sole basis for Applicants' Motion for Summary Disposition, if one were to accept the Applicants' statement f7/. Were Applicants able to convince ths'3 card and the KRO Staff thdt it is permissible to ignore all other design loadings (because of f7) $ff/.davitatpage3: "In that seisnic loading is the design determining force for virtually all piping supports, the pr14ci' pal issue here, this affidavit will focus on the safety margin which stems from consideration of seismic design."
~
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l Applicants' f a?.lscious preetse), it 'would also all0w them to be a' ole to ignore the numerous probleis eveountered in the nydrostat.ie and hot funct,ional tests; and receit(ag would nct aves be necessary. See also pages la and 14a of CASsE 8/29/84 Partial Answer to Applicants' Ststenent of Itaterial 7acis As to Which There Is No Gendine Isstre Regarding Applicants' Use of Gencric Stiffnesses Insteld of
- Actual Stiffnesses in Piping Analycis.
,yPSSRE. WALSH AND D0Y7K: {
?~a
- 7. Appl.tcasts utates .
The minibug safety factor conservatively qitantified for dynacic 16 ads othe,r than those resulting from a seirmic eveng is on the oydet of 5.0
/.Td. at 41) and iaciadas the specific f actors noted in item 2e, f , i, l7k,1sne3, above, id. This safety facter deem net tae.'.uda margins inherent ic the c9mputat$on of dynamic loads. Jd,. "
See adsyar 2 preending.
, h. Applicants state:
' Th6 minisas safety f actor conserva:ively quantiff s0 for stati; loc.ds is 1.68 (Ii. at 61) and includes ths specific f act'.r.s noted in iters 2k sud 1, above.. Id."
See answet 2 preceding. V3. WALSM: - Alsn, neither of up has'hsd time even to scan the transcript of the .
$/6/84 Applicants /NRC Staff / CASE telephone conference cril kr.Doyl}was _
p 21
~
=- _ - , , -, _ _ ._.
not on that call), the transcripts of the 8/8/84 and 8/9/64 Bethesdn meetir.gs between the NRC Staff and the Applicants, (all of which were just received by CASE on 8/22/84), and of course, the transcript of the meeting held _ at Comanche Peak 8/23/84 between the NRC Staff and the Applicants. Also, it is my understanding that there will be sone changes (at least one substantive) to some of Applicants' Affidavits regarding some of the Motions for summary Disposition and that by 8/30/84 the Applicants are to provide the Staff with several documents relating to the Motions for Summary Disposition (which obviously I also need to adequately answer Applicants' Motions). I would have liked to be able to do a more thorough job, and weald
~
like to be able to supplement my testimony af ter I have had a chance to review the referenced transcripts, changed Affidavits, and additional docu5ents. Attachments: Attachment A 7/26/84 ENGINEERING NEWS RECORD article, "Hyatt hearing traces design chain" -- see answer 2, page 6 Attachment B 3/11/84 Memo from M. Bender, NRC Advisory Committee on Reactor Safeguards ( ACRS), Washington, to D. Okrent and ACRS Members -- see answer 3, page 11 Attachment C 7/4/84 TUGC0 Office Memorandus to G. Grace from G. M. Chamberlain,
Subject:
CC-1-028-024-S33R -- see answer 3, page 15 Attachment D 7/4/84 TUGC0 Office Memorandum to G. Grace from C. Ray,
Subject:
AB-1-23B -- see answer 3, page 15 M 22
~
T ~ __ ~ . es
E The precedicg CASE's Answer to Applicants' Statement of Material Facts As T9 Which there is Fe Genuine Issue was prepared jointly under the personal direction of the undersigned, CASE Witnesses ekDoyleandMar_k) We can be tootacted through CASE President.hs. Juanita Ellis,1426 hlsh G. Polk, Lallas, Texas 75224,214/946-9446] Cur c;ualifications and background are already a part of the record in r.hese proceedings. (See_ CASE Exhibit 842, Revision tohsume of Jack Doylh acceptedintoe.videnceatTr.7042,andCASEExhibic841,Revisiontokesume of Mark Valsb accepted into evidence at Tr. 7278; see also Board's 12/29/83 Meteor 6ndum and Order (Quali;y Assurance for Design), pages 14-16.) We have read the staten6ats therein, and they are true and correct to the test uf ocr h-cvledge and belief. We do not consider that Applicants have, in the.tr Motiet! for Summary Cisposition, adequately responded to the isisusA raistd by us; however, we have attempted to comply with the Licensing Board's directive to inscar only the specific statements made by Applicants. (Signed) Mark Walsh - STATE OF ';IT.AS On this, the_ 2 9 day of [ M // p> 1984, personally appeared (Mark Walsh] tigwn to me to be tad person whose name is subscribed to the foregoing ir.stron, ant, and acknowledged to me that he executed the same for the purposes therein expressed. Subscribed and sworn before ma on the ,26 day of C/uEv.tca/b 1984 G
)~ ']4^ 9f.aku N'K hy Public in and for the State of Texas My Ccesission Expires:
SAMUEL W. NESTOR My Comrrassien Capires 13145 L II C' y ., -y g- - -
b The preceding CASE's Answer to Applicants' State =ent of Material Facts As To Which There Is No Cenuine Issue was prepared jointly under the personaldirectionoftheundersigned,CASEWitnesseshekDoyleandMah hh] We can be contacted through CASE President,(Mrs. Juanita Ellis,1426 S. Polk, Dallas, Texas 75224,214/946-9446) Our qualifications and background are already a part of the record in '
+- these proceedings. (See CASE Exhibit 842,RevisiontohueeofJackDoyle]
- . accepted into evidence at Tr. 7042, and CASE Exhibit 841, Revision to Resune ofhrkWalsh]accepteaintoevidenceatTr.7278;seealsoBoard's 12/28/93
. Memorandum and Order (Quality Assurance for Design), pages 14-16.)
1 We have read the stata=ents therein, and they are true and correct to the best of our knowledge and belief. We do not consider that Applicants have, in their Motion for Su= mary Disposition, adequately responded to the issues raised by us; however, we have atte=pted to comply with the Licensing Board's directive to answer only the specif c statements made by Applicants, f i (l 'c4u S1 .ned) JackDoylp } Date: /3 it f7 M /M[d STATE OF h o M a ,3 COUNTY OF Ne.w On this, the 1E R day of ku e u ,I , 1984, p?rsonally appeared (ack J. Doyle]knom en ine to cQ the person whose name is subscribed to the foregoing instru=ent, and acknowledged to me that he ! executed the. sa-e for the purposes therein expressed. Subscribed and sworn before ce on the 1sk day of Cu. t , 1984 0 Ym D. Notary Public in and for the (' ! State of %h eb . .. I My Coccission Expires:
.MY COMM SSION EXFtpEE SNUARY 9,1987
. ENW Contents July 26,19M, Vol. 213 No. 4 /d"TACS'ENT A _
a .. , .. w q g ps .,r. 3 ., , .
. stews
*Y**f . ff }', e." W f 5 20 Big plans for capital roads
. .' - jcv 4 R*yf %'p. '.g [$.,7 12 Hyatt hearing traces design chain g p -13 Sabotage delays pipeline opening
. e 21 Pans-Cologne hnk studied L '4, y J.,,s-e7.:4'.k. - 14 Beavers blamed for tram wreck 21 Movable bndges to be replaced
;4 p5 h'
- ,i Wz. A.'. [ ; q ..c . < -
15 More nukes bite the dust 22 New nuke waste plans eyed
.'4 w 'i'.. 15 Democrats downplay unions 22 Waste plants' increase backed by
- f. ,; 16 EPA tightens toxics permits pnvate cash 3 '^gg ,. , F w ' . l' -. .. . . , 16 Acid enhances sulfur removalin 23 Hydrogen sparks Canadians
; - pollution contro! works 23 Giant waste nnn taps landful gas
.~ '- , .- -> 17 Alaska bridge funds okayed market
" . J. g . n .., i * - 17 Interstate fundmg lapse tries 24 Toxics deanup battle ends
.. 1 ; 23 ;>
states' ingenuity 24. Waste to power hospital
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58 Safety rules remam in government abyss ' 26 Pragm.usm (Carr) 58 Panels cut state's A-E suas 59 Kickback ruled deductible 59 Court cases boycott rules
- . 59 Electncal firms charged with rigging bids
' consermanen Econandes
"$ 46 Materials Prices-brick, time, plaster, metal sheets and roofmg 50 Unit Prices-Close race for I-680 project 53 Market Trends-cost indexes, new plans, biddir:g volume
.i Departments 5 Construction Week
. ,- 7 Washington Observer 9 To Fill You In l
46 Pulse-bids, plans, contracts , l 12 Precedent i
. 64 Eastoriais
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l 2.?R Construction Week Granite slipping frorn Pittsburgh tower- Contractors' cash flow slows-- ne 13-year old Pittsburgh National Bank Building may After experiencing fewer problems with bill co!!ection need to have its entire granite skin resecured at a cost of as througho it most of 1983, contractors' cash flow slowed much as $5 million. Many of the stainless-steel fasteners slighdy during the first three months of this year, the latest secunng more than 4,000 slabs to the outside of the 30- period for which figures are" available from TRW, Inc., story building, on one of the city's busiest coiners, have Cleveland. Contractors in six of seven categories experi-loosened. A problem was first noticed last fall. Now, from enced a drop in the percentage of current accounts receiv-25 to 100% of the 800 to 1,600-lb slabs need to be able during the first quarter, only metal work contractors l resecured to prevent "a possible catastrophe," says a bank showing a slight gain. Still, those subs collected only 10.8% official. ne repairs could take as lor g as 2 years. of their bills on time, the lowest of all construction catego-r:es. Of the others, gensral contractors reported the highest
.Three Mile Island clean,up-share -of current accounts, 87.6Kr. .and heating and air Workers were set to lift the head of General Public Utilitv's damaged Hree Mile Island unit-two reactor this week. He Iraqi-Saudi pipe link to be bid next rnanth-lift is the next major step devised by cleanup manager Bechtel Power Cor2., San Francisco, on the road to defuel- Ir2q 'has imited bids on construction of a 400-mile crude-oil-ing the reactor infuly,1985. ne 156-ton head was to be pipeline to run from its southern oil fields to Saudi Arubian lifted from the vessel and moved to a shicided storage oil lines. Bids are expected by August i1. Construction is to ' stand. A hollow metal cylinder was to have been placed on begin in September. Cost is estimated at $500 million to Si !
top of the vessel for shielding. He cylinder will be filled billion. Basic pipeline design his been completed by Brown with water and covered with a lead and stainless-steel plate. & Root. Inc Houston (ENR 3/29 p. 5). A $2-b~.llion second ne underlying plenum is set for removal in the spnng. phase of work will continue through Saudi Ambia. I LILCO struggling with bankers for cash- Pressurized-pipeline studies- - l i ne Long Island Ughting Company, Miner,In N.Y.. strug. Battelle Memorial Institute's laboratory at Columbus, Ohio, gimg to avoic, bankruptcy, is trying to cc.mme .1 consor- plans a multiclient study of stresses induced in existing
. num of U.Sc and European banks to exten.1 me ampany pressurized oil and gas pipelines when new roads are built
.$200 million in credit using accounts receivsH .md stored over them. He institute's researchers believe that present oil as collateral. He utility's long batde to somplete its design guidelines are overly consenative, leading operators
$3.6. billion Shoreham nuclear plant has lett it deco in debt. to undertake the unnecessarily cosdy measures oflowering ne $200 million could keep 1.n.CO goinv ~
umil the end of a pipeline, installing casing or replacing the pipe. The
- 1985 if the New York State Public Semce Cummisson also insutute is seeidng $10,350 in financial backing from inter-agrees to a $281.million rate increase. ested companies.
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->. . U. ma; Hyatt hearing traces design chairi e
During tense cross-examination last International Inc., St. louis; its presi- could lose their licenses to practice in {$ , week, the steel fabricator for the Kansas dent, Jack D. Gillum; and vice president Missouri, have their licenses tem the Cary Hyatt Regency hotel said the con. Daniel M. Duncan with gross negli- suspended or be reprimanded. porarily,I " . nection believed to be responsible for gence, incompetence and unprofession- d lever after layer of detailed tesdmony the hotel's walkway collapse was the al conduct (ENR 2/9 p.14). has unfolded to expose conflicting views
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Engkwer Gaum (seated left) mnfers with towyers about heenngs so detemune fase of tus I,oenee. Duncan was GCE's protect engineer for hotet g caly steel.to-steel connection in the of the events stnrounding the construe. building that his firm and its subcon- N tion of the walknys. De walkways, di- rod tractor did not design. He maintained that the cridcnl connection had already - rectly above one another at the hotel's second and fourth. floor levels, were yf, been designed by the en q, supported by welded steel box beams. hired to design the hotel,gineerings structure: firm *- c;,3
,,,,,, De beams were suspended from the The tesurnony came at a heanng m, co cno,. ceilmg by 1%.in. steel rods and were to I St. Louis that could deternd~ the fu- attached to the building structure at ci- an#
ture careers of the structural engmeers co,cun o,. M involved. It started almost exactly three years after two pedestrian bridges cross-m o*ot ther end. In an investigation of the collapse, the ["' National Bureau of Standards found mg the hotel's atrium fell, lulling 114 #3'". that a connection design change, in persons and injuring over 200 others. which continuous support rods were re. 6a
'Ihis " battle of the experts, as one placed with pairs et offset rods, was a g,
lawyer called it, could set a precedent / critical factor m causing the failure. If t defining the responsibility implied by a the original design had been retained, I"{ g structural engineer's seal. De heanng the connection could have supported may also unravel the tangled chain oT Two roos swponsa waAs e accust omegrs responsibility for the Hyatt walkway the weight of the walkways and the peo-pie on them at the time of the collapse, Dj failure. da-De petitioner 'm the case before the Nas said (ENR 3/4/82 p. I!). Gillum was chief engineer for the de- Grmd. Willi,m G. Richev. of steel C "' Missouri Administrative Hearing Com- sign of the Hyatt. and Duncan was proj. fabricator and erects,r Havens Steel Co.. *" i mission is the Missouri Board for Archi- ect engineer. If the charges are uphefd Kansas City. Mo., was grC!ad bv defense "** i tects, Professional Engineers and Land by the state administrauve law judge, auomevs and the judge himelf. Richev Suneyors. ne board has charged ccE James B. Deutsch, the two engmeets admitted that while the Hyatt was in g'y; 13 der 4My att 1984 l l
design. Havens had too much work. one. rod system and the difficuhy of sponsibility found in contract docu-The firm sent panly completed shop buying single rods 46 ft long. ments. Plaintiff attorneys cited drawings to a subcontractor, steel detail- Defense attomev I.awrence B. Grebel documents mentioning the Ansc Code
! er WRw Engineering, Kansas City, Mo., presented documents showing that in of Standard Practice: " Approval [by the for compleuon. Richey said Havens and February, 1979, after Richey claims owner and its representauves, the archi.
WRW detailed more than 100 connec- Duncan had told him to use two rods, tect and engineer) constitutes the own. _ tions in the hotel atnum, and that for Richey was still having discussions with er's acceptance of all responsibility for many of them engineers on the detail- others about splicmg rods together to the design adequacy of any connections er's staff calculated loads and sized make up the 46.fr length needed in the designed by the fabricator." members. Gillum and Duncan say they single-rod design. Defense attomeys, on the other hand, I never knew of WRW's invohement. The buck stops. A key issue in the cited general conditions in the specfua.
,.* Richey maintained that cct designed case is the responsibility implied by a tions such as: " Approval does not re.
the criocal walkway connection. "Are structural engineer's seal. "According to lieve the contractor of responsibility for "f8IY you trying to tell this court that the one Alissouri statute, ultimate responsibility errors or omissions." . and only steel-to-steel connection that rests with the structural en ~ eer, no Judge Deutsch observed, '"Ihere are "Y was totally designed (by the structural matter what." said Patrick h! ey. at- disclaimers of responsibility that let any.
8 engineer] was the box. beam-to. hanger- torney for the licensing board. SicLar-. body blame everybody else."
Second chance. Considerable testi-l a.r a, 3 , *g3 % $ : 7 mony Concerned a Collapse or part of 6 ;> fpp .w, ? i ' <
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4 the Hyatt atrium's roof dunng construe. 3 ; .%; -: % tiorb.-an accident in which no one was
* ;31 t ~W .r. g' ;,g3.h , w>gg@,%..: ' f p-q.. t .' : i- injured. At this point, Siclarney says, t .-
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,1 1..- D But the plamtiffs presented a report
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"We then checked the suspended
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i Z',w,T a. nk? j'-c' $ The hearing was originally slated te _, gr.3k-:-- ; ' q ,E-:~ .
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' 3f' # *. may be recessed unc! mid-Aug tst and tyneewous test coaspee luneo 114 persons ano nureo ovw 200 omers at ar.amoon tea cance. coritinued then. The judge's decision is
. not expected until the fall. a d{ r d connection?" asked defense attor- ney cited the statute. 'Any registered nev Reeder R. Fox. If there were engmeer who afnxes ,m si ture and gg98 g gY tel's
,ere others, I'm not aware ofit." said Richey. personal seal to anv such p s. .shall Opening Of pipeline
""8 -
Richey was alsor questioned on a cru- be personally and pmtesuonally respon-the cial phone call that he clauns he made sible therefor.' to Duncan at ccE to clear up a discrep- A plaintiff expert wnness, Richard F. Apparent sabotage of a 100-mile, natu-ancy in a structural drawing. In that Ferguson, a retired engineer who ral-gas pipeline m Alaska will ettst the drawing one view of the second and he!ned wnte the American Instimte of owner about $400,000 to repair holes th f unh-level walkways shows a single, Steel Constructien (A:sc) specifications and check for others. But the anti ' t-1
""j conunuous rod supporting both. But a for structural steel design, said the engi- ed fall opening of the newly ins ed detail on the same drawmg indicates neer of record usualh has to delegate line wdl only be delayed by 15 to IS
- that a rod should terminate under both his duties because there's too much days.
'* the second and fourth-level walkways, work. "But he cannot delegate his re- seven holes were found recently in a g7 irnptving a double. rod design. sponsibilit ....There has to be a point 6-mile section cf pipeline near Eagle "d 'e Rdhey says, "He indicated to me to where the buck stops." River when water tests .showed lost ",y make it two rods. linformed WRW what The defense maintains, on the other pressure in the lower portion of the
- Duncan informed.me to do." hand, that it is the " custom and practice pipe. Work crews dug up a section of ' ~
, Duncan issued a press release on the in the construction industrv" for the the %-in.-thick pipe buned 11 ft be-P5 day of this testimony d-ming that this steel fabricator's engineers' to design neath a creek that tiows into Eagle Rher i ',,i conversation ever took place. Defense connectic,ns. In that way, fabricator- and found %.in. to 3/16.in.-dia boles l -
attomeys, using Havens purrhasing doc- crecters can choose details that suit the drilled through it. Sabotage,is' also'sys ' yo uments and , speed memos" as esi- equipment in their shop and the experi J pected on a phr line in western Mnn-dence, maintain that the change to two ence of their workers. ; 16).' W .4 hv
'n rods was a result of Havens' and WRW's Discialmers. Both sides traded para. tana (Dat "Ul9 Spokesman Danp;iel Dieckgraeff, of En-concerns about the contrucubility of the- graphs of boilerplate language on 're- star Natural Gas Co.,-Anchorage, a sub.
atR/.uy a 1984 13 W' - - - - - . _ __m_____--_ _ _.a m,, __ _ __.e $
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!,' y , ,, , g NUCLEAR REGULATORY COMMISSION 2- - g ADVlsORY COMMITTEE ON REACTOR SAFEGUARDS
. [ w Ass tNGToN, D. c. 20555 s., v p
***** Marcn 11, 1983
- ATTACHENT B ,
MEMO FOR: D. Okrent ACRS Members FROM: M. Sender,
SUBJECT:
SUGGEST!0x$ FOR THE LETTER ON ACCIDENT PRECURSOR STUDIES (APS) As noted in tne Reactor Safety Study Review Committee Report, the examination of accident precursors can provide very useful safety information. Tney can snow:
- 1. wnere impruved maintenance practices are needed (e.g. , tne Salem circuit break ers ),
' 2. whether tnere are adequate diagnostic capabilities to indicate impending problems and now to control tnem,
- 3. wnetner plant operating procedures are adequate and effective, l
4 deficiencies in engineering design, construction and application of plant systems , controls , and components,
- 5. tne stage at wnicn accident consequences can be controlled most effectively,
- 6. effects of plant aging on safety,
- 7. quality deficiencies tnat may nave been overlooked.
- 8. adequacy of 10 CFR 50 requirements (e.g., single failure criterion)
None of those purposes appear to have been addressed by tne APS studies thus far performed. Most of the effort has been directed to the implications of accident precursors in probabilistic risk assessment. Tne results of tne Oak i Ridge-SAI work and the INPO review of tne Oak Ridge effort snow clearly tne reason wny PRAs are not good measures of safety adequacy. 53 cucn subjec-tive judgment is involved in tne probability evaluation tnat tr.2 results cannot be trusted for absolute risk measurement. Comparative results based on a consistent judgment basis can, of course, provide useful insignts. Tne Oak Ridge work was a useful pilot study but did not really identify any new matters needing attention. Its screening metnod is usable for some types of PRA work but does not really serve tne needs of 'otner aforementioned purposes. Other screening criteria should be sougnt. J. fn'- /
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.t; Okrent/ACRS Memeers Marcn 11,1983 Tne study effort snould include entire cnains of events for important pre-cursors. For example, tne Browns Ferry fire event should include tne frequency of fires initiated at tne barrier penetration seals and the THI-2 event should include contricution of tne TMI-demineralizer resin problems to the accident sequence and tne system interactions from tne instrument air system that initially upset tne turbine concenser controls.
Such studies need careful review but little purpose'is served oy using tne . original WASH-1400 participants as reviewers'. Ineir oejectivity is certain to be cnallenged. Tne INP0 review was obviously directed to refuting tne Oak Ridge study 's probability jucgments. Tne lack of a qualified statistician to assist in evaluating the use of statistical data makes the value of tnese reports questionable. Tne industry groups sucn as INP0 or individual utility groups are best able to perform tne APS work. But tne groups should include a good selection of system and equipment specialists as well as statistical and probability analysts. This activity again points up tne problem of using "PRA" type studies as the basis for public safety assessment. In tnis case it has led to con- . siderable wasted ef fort to explain numerical values. It did not pnysically ennance plant safety. cc: R. Major, ACRS R. Fraley, ACRS H. Liearkin, ACRS J. C. McKinley, ACRS Page Revised: 3/14/83
Aw'- . An ACE ~E:C C
- TEXAS UTILITIES GENERATING COMPA.W OTTICE MEMOR A NDUM July 4, 1992 ci,, m,, 7,,,
To G. Grace __ Subiect CC-1-028-024-533R -
. From the attached STRUDL analysis without the skewed bolt at joint 10, the bolt. interaction for joint 12 is the following:
~ x- Fo rc e = 96
- y- Force =47 a7
- z- Forc e= 6471 d
= 0.wS3 e 1 (ok) th +
The bolt interaction for joint 14 is the following: x - Fo rc e = 214 = y- Fo rc e = 9740 = z- Fo rce = 6362 = 7 2 97 0 - 365 .
= 1.40*
gg .+ g
'In this case a 30% overstress of the bolt does not mean failt.re b:;; only a reduced factor of safety. In this case it is an absolute worst case condition In actuality be-cause we are assuming no f0rces are being resisted by the cented bolt.
the tremendous ductibility of the A36 rod at joint 10 woulc resist so e of the load and reduce the interaction at joint !c. Very Truly Yours, i 1 i L i G.M. Cnameerlain i
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ge, . (,,f UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ] I TEXAS UTILITIES GENERATING l Docket Nos. 50 445-1 COMPANY, et al. l and 50-446-1 I (Comanche Peak Steam Electric Station l Station, Units 1 and 2) l CASE'S PARTIAL ANSWER TO APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE REGARDING APPLICANTS' USE OF GENERIC STIFFNESSES INSTEAD OF ACTUAL STIFFNESSES IN PIPING ANALYSIS in the form of AFFIDAVIT OF CASE WITNESSES CK D0YLE AND MARK WALSH MR. WALS
- 1. Applicants state:
"In conspting the response of a piping system which is either ASME Safety Llass 2 or 3, Applicants use generic stiffness values. For Safety Class 1 systems, Applicants use the actual suppart stiffnesses.
(Iotti, Finneran Affidavit at 2.)" I agree with Applicants' statements insofar as they apply to the piping system. However, the problem which is at issue here is the pipe support groups do not calculate a stiffness for the supports for ASME Safety Class 2 or 3. A stiffness value, as an example, would be 5,000 lbs./ inch; that is, a support will move 1" for a 5,000 lb. load. The pipe support groups use a generic deflection criteria, rather than a generic stiffness criteria. The generic deflection criteria is a x FCIA-85-59
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- 1/16" deflection, no matter what the load is. In other words, the piping analyst assumes the pipe support is in compliance with a generic stiffness requirement, but the pipe support groups do not calculate a stiffness. This procedure is in conflict with ANSI N45.2.11 (to which Applicants are committed), specifically 3.1 and 3.2 r
which state, in part /1/:
"3. ' DESIGN INPUT REQUIREMENTS "3.1 General
" Applicable design requirements, such as design bases, regulatory requirements, codes and standards, shall be identified, documented and their selection reviewed and approved. Changes from specified design requirements including the reasons for the changes shall be identified, approved, documented and controlled.
"The design input requirements shall be specified on a timely basis and to the level of detail necessary to permit the design activity to be carried out in a correct manner and to provide a consistent basis for making design decisions, accomplishing design verificajien measures, and evaluating design changes.
"3.2 Requirements 1 "The design input requirements should include the following where applicatle:
". . . (2) Performance recuirements such as capacity, rating, system output."
I (Titles emphasized in the original; balance of emphases added.) fl/ See Applicants' Exhibit 148, ANSI N45.2.11, Draft No. 2, Rev. 2, May 1973, admitted into evidence at Tr. 5398 (supplemented, Addition to L Applicants' Exhibit 148, following Tr. 7014). f 2 l t. 7
I i 8 4 I MR. DOYLE:
- 2. Applicants state:
"The use of generic stiffness values is a common industry practice and has been found acceptable by the NRC provided that the generic stiffnesses adequately represent the stiffness of the installed supports (Iotti, Finneran Af fidavit at 2-3.)"
I agree that the NRC Special Inspection Team (SIT) made this statement, in the SIT Report (NRC Staff Exhibit 207), page 40, last paragraph:
"The use of generic stiffness values is common practice and is acceptable provided that the generic stiffnesses adequately represent the stiffness of the installed supports."
While I cencur with this statement, I do not agree'that the actual stiffnesses of the installed supports adequately represent the generic stiffness used when all elements which contribute to the stiffness are considered in the actual stiffness. For example: (1) In the event a strut /U-bolt structural frame / anchor baseplace arrangement are all in live between the node point of the pipe and the hard point of the building, the following actual stif fness would apply generally for all supports affected by loads of less than 8,000 lbs. in the normal upset case: The strue extension pipe for 50 inch length 1-1/2" diameter has a stif fness of less than 400 k/ inches. The U-bolt 5/8" diameter has a k f actor equal to 100 k/ inches. Assuming the structural frame is maintained at the 1,000 k/ inch stiffness and the anchor bolt baseplate assembly has a k factor of 500 k/ inch, 'l
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the combined k for this support would only be 69 k/ inches or approximately 1/70 of the generic stiffness utilized in the pipe stress analysis at CPSES. ' (2) The Applicants' generic stiffness study, which was performed for an as-built system and included only the structural stif fness and strut stiffness (but not including excentricities such as indicated on drawing No. CC-2-011-001-A73R, CC-2-011-003-A73R, and CC-2-011-005-A73R -- this last support also has about a 12 degree kick angle). These supports are unstable structures which depend on the torsional stiffness of the pipe to establish the ultimate stiffness of the support. (For these supports, see Motion for Summary Disposition, Generic Stiffness, discovery item 9, document set No. 1.) Nor were the stiffnesses of the U-bolts or base place anchor bolt assemblies considered. Applicants' new generic stiffness study indicated that the generic stif fness f actors were not represented in the installed supports, and in fact, for the 6" line, the actual stif fness varied from 3.6 times the generic value to 1/70 of the generic value, and for that case 75% of the loads increased and were therefor = nonconservative. The maxinum increase for one support was 200%; 20% of the supports exhibited load changes greater than 25%. And it must be mentioned one more time, these stiffness values did not include the ef fects of U-bolts, base plates, anchor bolts, gaps, etc. The greatest load increase in terms of actual load was one support, the load of which went from 824 lbs. to 1371 lbs. At one anchor, force and 4
~
- I e 4 one moment also increased more than 25%. At the other anchor, all moments and two forces increased, and it must be recalled that this was for a system with only one support at 1/70 of the generic stiffness, and as shown above, the pos.*1bilities for many systems with one or more soft supports (1/iO) exists f2/.
(3) Recalculation of support loads was also done for support No. CC 107-008-E23R, which was a support that had a generic stif fness of 1/360 of the generic stiffness. The load increase in this i particular support was over 600% and resulted in a redesign of the support by CMC 94130, July 29, 1983 f3/. (4) The fact that the effects of U-bolts, struts, etc. influenced the dynamics of systems while apparently not a concern of the Applicants or NRC Region IV, is an express concern of the Commission. See ASLB 12/28/83 Memorandum and Order (Quality Assurance for Design) at page 38, quoting Board Notification 82-105A, IV, pages 4 and 5, which states:
"The dynamic interaction between the pipe and pipe clamp is a complex design problem. From a design standpoint, there are many uncertainties that could affect the actual system
! response such as consideration of total support system ! flexibility, mechanical non-linearities, construction and installation tolerances, and uncertainties in the dynamic loading itself. It is beyond the scope of this report to
/2/ See,yRC Staff Witness W. Paul Chen's Affidavit on Open Items Relating tolWalsh/Doyl(IConcerns(undercoverletterof 10/14/83), page 24 and l
Attachment (Applicants' 8'/17/83 Additional Pipe Support Ceneric l Stiffness Study). f3/ See Chen Affidavit, pages 25 and 26; see also drawing, CASE Exhibit 669B, Deposition /Testimonyoff{ackDoyle}admittedintoevidenceatTr. 3630, item 11TT. 5
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discuss the clamp-tc-piping responses to these various factors. However, che report will focus on those local dynamic effects ca the piping that can be attributed primarily to the clamp attachment that, in general, are not explicitly evaluated by piping designers." (5) Therefore, the seismic analysis is rendered nonconservative due to the fact (s# shown above) that the generic stiffness values are not rep;csentative of the supports as used at CPSES. (6) The facts are that the use of generic stiffnesses represents a gross concern for the design of CPSES and is in violation of the codes and laws to which Applicants are committed. The chain of codes and laws is as follows: (a) In accordance with the provisions of ASME Section III, NA-3250 (PROVISION OF DESIGN SPECIFICATIONS), Applicants prepared a technical specification for nuclear safety-related equipment; (b) The title of the document generated in compliance with ASME Section III, NA-3250, is NUCLEAR SAFETY CLASS PIPE HANGERS AND SUPPORTS, SPECIFICATION 2323-MS-46A; (c) ASME Section III, NA-3320(b) regarding Manufacturer's responsibilities, is directed to ASME NA-3340; and NA-3340, RESPONSIBILITY FOR COMPLIANCE WITH THIS SECTION, states:
"The Manufacturer who completes or substantially completes any component, appurtenance, core support structure, or component support required to be in compliance with this Section has the responsibility for the structural integrity using the Design Specifications as a basis of design . . ."
6 h.
(7) The practices used in the design and construction at Ccsanche Peak nuclear plant proceed under a false premise; that is, you construct the f acility, then justify the construction as opposed to justifying the procedure and then constructing. f 4/. (8) CPSES practices evade the provisions of 10 CFR 50, Appendix A, Criterion 1. (9) Also, CPSES practices evade the provisions of 10 CFR 50.55(a)(1) design to standards commensurate with the safety function. (10) CPSES practices evade the provisions of 10 CFR 50.34(a)(8) on the requirement to prepare a plan for research and development for unique designs in the PSAR. (11) Applicants' position is that it is industry practice to use the generic stiffnesses -- even though Applicants admitted that they are not in a position to state that the 1/16" deflection criteria always guarantees that they meet that generic stiffness f5/.
- 3. Applicants state:
" Applicants have conducted reanalyses of three piping stress problems using actual support stiffnesses effects both prior and in response to the Board's December 28, 1983, Memorandum and Order (Quality Assurance for Design). (Iotti, Finneran Af fidavit at 4-10. )"
See discussion in answer 2 preceding. 24/ For other examples of " preliminary" construction, see CASE Exhibit 669B (Attachment to Deposition / Testimony of('ack L Doyle):] 8T and 8U, 8V and 8W, 80 and BR, SS and ST, 11TT, 11UU and 11VV, 11WW and 11XX, 12H and 121, and 135. f5/ See Transcript of 6/6/84 telephone conference call between Applicants, NRC Staff, and CASE, page 93. 7
~
i . . MR. WALSH:
- 4. Applicants state:
" Applicants reviewed a total of about sixty supports as part of their reanalyses to determine stiffness effects. Of the sixty, only four experienced increases in loads in excess of a factor of 2.0. All four-were originally lightly loaced. The reanalyses demonstrateed (sic) that only three of the sixty supports (le , than 4%) would now have calculated loads which exceed allowable values. All three supports have snubbers. For two of these supports, only the snubbers themselves were computed to experience loads which excee; the manufacturer's rating. (one exceeds its racing by 14% and the other by 57%). The remaining components of these supports are sichin specified design allowables. The third support is computed c3 be overloaded (exceed the allowable by less than 5 percent). In no lastance were recalculated nozzle or anchor loads or pipe stresses found to exceed allowable values. All other supports (frames, components, and base plates of these supports) are within specified design allowables for the recalculated loads. (Iotti, Finneran Affidav!.c at 19-20. )"
The reanalysis reflects results similar to the previous reanalysis which was conducted for the SIT team. That is, some supports will increase in loads in excess of a factor of 2.0, and some supports will exceed established code allowables. I disagree with Applicants' statement that pipe stresses were found to be within the allowables. The reason for my disagreement is as follows: When a support has exceeded the established code allowable based on yield strength, the support is acting in a plastic manner. This plastic behavior will transfer its intended load back into the pipe, which the Applicants did not consider. Their analysis was based on elastic behavior and, although a support had exceeded code allowables and could not take any additional loads, the elastic analysis erroneously assumes the support is still capable of supporting a load and thus does not redistribute 8
this load back into the piping system. For this reason, the Applicants' position that pipe stresses and other supports were within their allowable stresses is unsubstantiated. I asked for and received on discovery the drawings of the 60 supports referenced by Applicants, along with the calculations for the drawing which Applicants consider to be most complex f6/. Of the 60 drawings (actually 59 by my count) f7/, two of the drawings (MS-1-01-003-C72K and JT-1-013-023-S42K) contained axial restraints by the use of welding trunnions to the pipe. The Applicants' present procedure does not consider the effects of the double stanchions' axial restraint or its consequences. Thi* is the subject of a separate Motion for Summary Disposition, which CASE has not answered yet. The results for the generic stiffness are misleading due to Applicants' present position that there is no problem regarding these axial restraints. Of the 59 drawings, 7 of the drawings (CT-1-013-022-S42K, CT 013-014-S32R, CT-1-013-007-S22K, CT-1-013-001-S42R, CT-1-013-016-S32K, CT-1-013-010-S22K, and CT-1-013-008-522K) contained cinched-up U-bolts. The Applicants' present procedure does not consider the effects of cinched-up U-bolts or its consequences. This is the subject of a f6/ See 6/6/84 Applicants / Staff / CASE telephone conference call Tr. 102-111. f7/ All 59 of these drawings were sent to the Board and parties as Attachment B to CASE's 8/13/84 Answer to Applicants' Motion for Summary Disposition Regarding the Effects of Caps on Structural Behavior Under Seismic Loading Conditions. 9
separata Mction for Summary Disposition, which CASE has not answered yet. The results for the generic stiffness are misleading due to Applicants' present position that there is no problem regarding these cinched-up U-bolts. Of the 7 drawings containing cinched-up U-bolts, 3 contain single-acting struts or snubbers (CT-1-013-008-S22K, CT-1-013-022-S42K, and CT-1-013-001-S42R). These three particular supports require (according to the Applicants' criteria) a cinched-up U-bolt to pecvide stability. Stabil,ity is also the subject of a Motion for Summary Disposition which CASE has not yet answered. Of the 59 drawings, 32 supports utilized tube steel members in becding, which I reviewed for the thinness ratio for punching shear. Of those 32 supports, there were 6 cases (5 supports, with two examples on one support) where the thinness ratio was 10 or above; 5 cases exceeded 10 -- although Applicants had emphatically stated to the NRC Staff that 10 was the largest ratio which exists at Comanche Peak ]8/. It is the Applicants' normal design practice not to consider the local punching shear stresses or their consequences. This was discussed in Applic(nts' separate Motion for Summary Disposition (see Footnote 8 hereco) which CASE has already answered. The results for the generic stif fness are misleading due to Applicants' present position that there is no problem regarding punchitg shear. f8/ See discussicn at pages 15-17 of CASE's 8/6/S4 Answer to Applicants' Statement of Material Facts As To Which There Is No Cenuine Issue Regarding Certain CASE Allegations Regarding AWS and ASME Code Provisions Related to Design Issues. 10
=- - - - - -- - - ____ , .._ _ _ ep
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Of the 59 drawings, 36 of the drawings 19/ contained tube steel members. The Applicants' present procedure does not consider the effects of the reduction in yield strength of the material due to welding and therefore uses a higher allowable stress. This is the subject of a separate pleading by Applicants (regarding A500 Steel) which is being treated as a Motion for Summary Disposition, which CASE has not answered yet. The results for the generic stiffness are misleading due to Applicants' present position that there is no problem regarding the reduction in yield strength of the tube steel members. In addition, the A500 steel section properties including the strength of the groove beveled weld based on the cross-section of the member is also the subject of a Motion for Summary Disposition (on section properties), which CASE has already answered. f_9/ CT-1-013-023-S42K, CT-1-013-011-S22R, CC-2-011-719-A53R, CT-1-013-002-S42S , MS-1-001-002-C725, CT-1-013-021-S42K, CT-1-013-008-S22K, CT-1-013-017-S32K, MS-1-01-005-C72K, MS-1-001-004-C72K, CT-1-137-701-S25R, CT-1-017-704-S25R, CT-1-013-020-S42K, CT-1-013-015-S32K, CC-2-011-721-A43R, CC-2-011-720-A43R, CC-2-011-718-A53R, CC-2-011-717-A53R, CC-2-011-715-A53R, CC-2-011-714-A53R, CC-2-011-713-A53R, CC-2-011-712-A53R, CC-2-011-711-A53R, CC-2-011-708-A63R, CC-2-011-707-A63R, CC-2-011-706-A63R, CC-2-11-702-A63R, CC-2-11-701-A63R, CC-2-11-700-A63R, CC-2-011-002-A63R, CC-2-011-001-A63R, CC-2-11-704-A63R, CC-2-011-703-A63R, CC-2-011-716-A53R, CT-1-013-016-S32K, CT-1-013-010-S22K. 11 E -- -- _ _ _ __
I Of the 5:e drawings, 33 of the drawings /10/ contained a connection that had a gap and these supports were loaded predominantly in shear. The Applicants' present procedure does not consider the effects of a gap in the calculation of their generic deflection criteria or the actual stiffness calculations that were provided. As shown in Attachments A, B, and C hereto, supports CC-2-011-703-A63R, CC-2 704-A63R, and CC-2-011-706-A63R did not consider the gap between the bolt and the base plate in their stif fness calculations; i.e., they assumed that no gap existed or they assumed a friction type connection which the Applicants do not design for. This is the subject of a separate Motion for Summary Disposition (on gaps), which CASE has already answered. The results for the generic stiffness are misleading due to Applicants' present position of assuming no gaps. A simple example can demonstrate the consequences of not considering a gap in the base plate. Referring to Figure 1 following, there are three identical (except for their base plate connection) supports labeled A, B, and C, which are supporting a pipe. Because A, B, and C are identical (except for their base plate connection), they
/10/ CT-1-013-012-S32K, CT-1-137-702-S25R, CC-2-011-710-A33R, CC-2-11-709-A63R, CT-1-013-018-S42K, CT-1-013-009-S22K, CT-1-013-023-S42K, CC-2-011-719-A53R, CT-1-013-002-S42S ,
MS-1-001-002-C725, CT-1-013-008-522K, MS-1-01-005-C72K, CT-1-137-701-S25R, CT-1-013-015-S32K, CC-2-011-721-A43R, CC-2-011-720-A43R, CC-2-011-718-A53R, CC-2-011-717-A33R, CC-2-011-715-A53R, CC-2-011-714-A53R, CC-2-011-713-A53R, CC-2-011-712-A33R, CC-2-011-711-A53R, CC-2-011-708-A63R, CC-2-011-707-A63R, CC-2-011-706-A63R, CC-2-11-702-A63R, ! CC-2-11-701-A63R, CC-2-11-700-A63R, CC-2-011-002-A63R, CC-2-11-704-A63R, CC-2-011-703-A63R, CT-1-013-016-S32K. 12 i r
all have an equel amGunt of stiffness and . supports A and C vill receive tn equal amount of load. For purposes of this example, it will be assumed that the support stiffness is equal to 1,000 lbs. per 1/16" deflection. But support A has a base piste that will transfer the load to the bolts in shear. However, since the base plate was designed as a bearing type connection and slippage is possible, suppors A vill
, deflect and have a different amount of stiffness now. This 6tiffness now will be 1,000 lbs. per 3/16" deflection assuming a 118" ovsrsize hole in the base plate. The result is the stiffness of support A is 3 tires less than thgt of supports B and C, and with the Applicerts' present procedure, this is not accounted for. The results of using incorrect stiffnesses is the snbject of Applicants' Motion, but Applicants not using e.ccsistent design practices; i.e., bearing type connections for the design of the base plate, fric: ion type cottrtection ,
for the stiffness or deflection calculation. p$ 1_y nN Y 'u
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l . In addition, Cygna has expressed its cotteern that Applicants have been using improper damping values. The use of the improper desping values indicates a decrease in load for tha suppor;s and a decrease in pipe stresses. This is discussed in CASE's 8/6/$4 Answer to Applicants' Statement of YJterial Facts As To 'a*hich There Is No Gennine Issue Regarding Applicants' Corsideration of Damping Factors for OBE and SEE Loading Cotidit!6ns at page 4, answer 2. (For instac'ce, since it is a 6" line, the component cooling system (CC) line ,14 one of the systems abouc whien Cygna expressed concern vnere Applicants are using improper damping fact. ors.) The Applicants' pr?sent precedure dcas not consider the effects of thsir use of erroneous dasping factors. The results for the genaric stiftness are misleading due to Applicar.ts' present position of disregarding their qse of impecper damping f actors. Also, an effett the Applicantg have generically not considered in
*:he?.r pipe a' cress analysif , which (culd have impact on the conclusion at which Applicante have arrived in their Motiong is mass participation: ,
"Gibbs & P.1].1 does tot perfern any additional analyser or cal:u?.ations tu enstre that the inclusica Gf additional godes does not significantly increase the response of tha piping systeu tnd result in htgner stresses and support lo ad s . /11/.
As Dy3na has statedt
" Consideration of responses in the tigid range (i.e., 2PA ef fects) '
maf :esult in eignificant*.y hf 3her support loads. . . che additional loads aesecfsted with this concern nay leed to failure of the pipe suoports earing s seistic event." /12/.
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/i!/ See[ Independent Assessmant Frogram, Final Ecport - Phass '3, Volume 1 ,
Appendix F. Potr.ntici finding Report, PFR No. 01, Cbservation Fo,'JT-00-03, page 1 ef 3.
/ IT / ,1,d_. , ;-a ge 2 o f 3.
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e i i Further information regarding this is contained in a document just
%A r Y i received from Cygna on 8/28/84 /12a4 This 8/25/84 letter from pr. N. ;
H. Williams, Project Manager, Cygna, to J. B. George, Project General . Manager, TUGCO, under Subject of: Phase 3 Open Items - Mass ; Participation, states, in part:
"Cygna has reviewed the reference (a) letter regarding a revision i to the Gibbs & Hill mass participation study. Since we have not -
i yet received the Gibbs & Eill preliminary report on the result of the revised ADLPIPE analysis . . . our reviewers are unable to fully understand the reasonableness of approaching the analysis in the manner proposed . . . Cygna believes Lt is necessary to t notify TUGC0 of the following concerns regarding the use of this revised approach: l ". The method proposed by Gibbs & Hill uses the higher of L the loads from the static ZPA analysis and the load from the i j dynaale analyses. This ' yardstick' for determining support I adequacy may be considered inadequate since this criteria g does not satisfy the requirements of the CPSES PSAR Sectien 3.78.3.1 . . . Checking that the support loads in a system equal the mass multiplied by the ZPA is a good review tool to determine the reasonableness of a dynaale analysis. If it is to be used for design purposes a study must be performed to demonstrate whether or not the ZPA approach ensures that
- the FSAR criteria is set.
". Cygna does not believe that a 10% increase in pipe support loads will be acceptable to ensure design adequaev.
.- Our review of the pipe support designs revealed that many of the supports do not have sufficient margins to accomodate an increase of this magnitude and stil meet Code allowables.
". Cygna does not agree with Gibbs & Hill's proposed reduction of ZPA accelerations below the value at 33 hz.
Justification is recuired to assure that the piping system does not have significant response between 33 hz and the frecuency at which the ZPA is taken. l l
/12a/Since this document was just received on 8/28/84, just prior to the
, running of copies, Mrs. Ellis telephons($r. Walsh]and read him the I document. He told her to insert it, what to say about it, and where to f insert it. A supplementary Af fidavit to this ef fect from[37. Walsh 3 will be sent when we send the next Answers to Motions to Summary Disposition. i 14a l-t - .- - . . - _ . . .. .- . .
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". Although ts have not reviewed the resulth of the revised l Gibbs & Hill a'salysis. Tyrna does not believe that this is ne can be resol.(d by sathplina worst _ case problems. Thls will quantify some of tha potential changes in support loads but will not demonstrate tan adge uccy of systems which are not analyzed. If Gibbs & Hill' desire's to continue, with the sempling approach, TUCCO should ,ansure that a portion of the sample includes $roblems located wi sin a single structure in order to sinisire SAM effects.'! (Emphases added.)
f A 9 9 9 14b f
t .. . . . l d For all the pre 2nding reasons, Applicants' reanalyses are invalid
, and the results they obtained (even including the overstressed snubbers) are actually working witn unrealistic and unconservative design assumptions and design analysis procedures,
- 5. Applicants state:
" Tests conducted on snubbers with the saine rating as the two for which the calculated loads exceeded manufheturer's raced loads (Pacific Scientific Snubbers rated ac 1500 lb. for normal and upsat iceds), have shown that the snu'ober will perfors its intended fun: tion at loads which are considerably higher than raced. In addition, the tested snubbers would still functica as intended duri'ag a se&ssic event, i.e.,
in locked position, at even highee loads. (Iotti, Fitneran Affidavit 4t note 10.) Thus, there is no real safet',r concern with these anubbers." Applicants have not shown that the tests referenced are applicatie to Comanche Peak. If a snubber is installed incorrectly or in the wrong location, it is reasonable to assume that .tt will nac perform its intended function. And, obviously, if 6 snubber is not even installed, it cannot perform its intended function. Considerabl6 doubt in ttils regard exists, as discussed in CASE's 10/13/83 Motion to Add A New Centention /13/. As discussed in that Motion, regarding the thermal expansion test (pages 26-34), 63 supports contaicing snabSers had the snubbers removed or the support zodified af ter tne thermal expansion test due to binding, 179 anubbers were not installed on the pipe supports during the test, one TDR was used to change the effect.s of one
*/13/ CASE's 10/13/83 (1) Motion to Add A New Contention, (!) Motion for Discovery, and (3) Offer of Proof.
3 15 g
- -. - - n support. from a scubher to a rigid pupport (of ci,gniricance because it was one of the speqific suppnets contained in CASE Exalbit 660B, Attachment t9 ( ack toyle',$) Deposition /Testimany), and meay of the stubbers that wera installgi had mechanica'. probiest fuch as binding, eseteding travel capabilitie.1, et ju,st being inoperaqive. The Applicants' position on this setmed to be to recove the Sou'obers during tb Tuarmal Expansien Test and *einstal'1 them later; thus, ther arr not cddressing the true prehlem, which is: k*hy die those sapports ,
malfunction te Segir. with? It thould be note,d thst thyrmal.txpansion testing is one of the tests which the NPC Staff has just approved for deletred recesting, os icdicated in Attachne.nc D he'retc /14/. As stated on paghs t and 3 of the Encionuce to : hat lotter:
"E. ICP-fT-55-11, Thermal Exesnsion pre .so-rations 1 Test *
"During the performance of the thermal exptnsion tett, a
number of teet dafieleue.ius :mre noted percatuir.g to enubbers, springs ,and suppcrts. These def.'.ciencies were et
. three cattgories:
"(1) installed items dia nbt meet acceptance crite-la;
"(2) installed items removci due to interferenced. and; '
"(3) items not inatalled for the test. .
"The applicant will,h,a3 corrected these deficivocies and proposes that the test be repea:ed af ter fuel load when the next plar.t heacup is cc.ipletnd f ar init'.al criticality.
Fihal cold settihg of recest items would be ac ouplished at the shutdowS se!.eduled at the end of t he 30.% po' Jar plateau.
/14/ 8/17/84 letter frcz B. J. You;gblood, Chief, Licensicg Brtach No. 1, Division 6f Licensteg, NRC, Washington, to M. V. Spence, President, TUCCO.
r 16
._. _ _ . . _ . , - _ _ - , . . .s . -
- a. . .
I 4
"The deferral of the thermal expansion retest is acceptable because it is consistent with approved industry practice on other plant test programs. Furthermore, compliance with Technical Specifications relating to piping ' supports will be required for plant operation to oroceed."
(Title emphasized in the original; balance of emphases added.) As stated previously, Ipplicants have not demonstrated that the snubbers they reference are applicable to Comanche Peak. And even if , i they were, the Applicants are trying to justify a fait accomoli because of an unsatisf actory result. Applicants would have the Board believe that the problem has evaporated, based on a test that the vendor does not certify (or it would alread} have been included in the original design). This is not acceptable. As'part of discovery on Applicants' Motion for Summary Disposition Regarding Safety Factors,1 obtained copies of most of the References shown on Applicants' Attachment 3. The document shown as Reference 4
/15/, is instructive regarding this particular matter; it states (Page 1-8, emphases added):
t "In addition to the parameters discussed in this report, three other considerations that affect the failure / survival , characteristics of structures and subsystems are design and i construction errors, aging, and construction practices. I Design and construction errors are earticularly troublesome. Thev introduce additional uncertaintv as to the capacity of a constructed facility. It is improper to accept errors as the status quo, to uniformly increase the uncertainty assigned to the
- analysis parameters, or to compensate for errors through inflated ,
l safety factors or mareins. The proper solution is tc practice L good quality assurance / control techniques to eliminate or
- effectively minimize the possibility for errors."
/15/ "American Society of Civi:. Engineers, ' Uncertainty and Conservatism in
~'""
i the Seismic Analysis and Design of Nuclear Facilities,' ASCE Dynamic I Analysis Committee, Working Group Report, 1983 (Draf t) ." See also further dis:ussions under answer 4 in CASE's 8/29/84 Answer to Applicants' Sta:ement of Material Facts As To Which There Is No Genuine Issue Regarding Safety Factors.
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- 6. Applicants statet
" Applicants' analyses provide reasonable assurance that for variations of actual stiffness from generic sti'fness less than one order of ragnitude (i.e. , less than a f actor of 10), .there is no adverse effect on the seismic response of piping systems. In addition, the tests indicate that variations in excess of one order of magnitude will, in general, cecur only for supports that have light initial loadings, which supports, because of the light initial loadings, are capable of accommodating relatively large increases in loads (Iotti, Finneran Affidavit at 7-10 and 15-20)."
Applicants have explicitly stated above that, when there is less than a factor of 10 from a generic stiffness, there is no adverse effect. Powever, NRC Staf.f Witness Dr, Chen /16/ stated that Applicants' supports at times d3L exceed 10 times the generic stif fness value whe:i utilizing the 1/16" deflection criteria. Where these supports do exceed the 10 eines generic stif fness criteria is not known and it has not been established which support egnfigurations do exceed 10 times the generic stiffness criteria. Further, as discussed in answer 4 preceding, Applicants' reanalyses are invalid and the results they obtained (even including the overstrested snubbers) are actually working with unrealistic and unconservative des!gn assumptions and design analysis pr9ceduras. m MESSRS. DOYLE AND WAlSH: w It should be noted that in this affidavit, due to the severely restricted time frame under which we were working, we split up the work load and each of us answered specific questions (as indicated herein).
/16/ See NRC 5tof t Witness W. Paul Chen's Af fidavit on Open Items Relating
~
~to({aish/Doyle} Concerns (under cover letter of 10/14/83), page 24 18
/
We did not have time to check one another's answers. We would like to have had sufficient time to do a more thorough job. f l MR. WALSH k Also, neither of us has had time even to scan the transcript of the8/6/84 Applicants /NRCStaff/CASEtelephoneconferencecallfr. ) (3ylk}wasnotonthatcall),thetranscriptsofthe8/8/84and8/9/84 Bethesda meetings between the FRC Staff and the Applicants, (all of which were just received by CASE on 8/22/84), and of course, the transcript of the meeting held at Comanche Peak 8/23/84 between the NRC Sta'f end the Applicants. 'Also, it is our understanding that there will be some changes (at least one substantive) to some of Applicants' Affidavits regarding soet of the Motions for Summary Disposition and that by 8/30/84 the Applicants are to provide the Staf f with several documents relating to the Motions for Summary Disposition (which obviously we also need to adequately answer Applicants' Motions). As stated above, we would have liked to be able to do a more thorough job, and would like to be able to supplement our testimony after we have had a chance to review the referenced transcripts, changed Af fidavits, and additional documents. Atta chments : Attachment A Drawings and calculations for support CC-2-011-703-A63R -- see answer 4, page 12 hitgeh::nt ; Drawings and calculations for support CC-2-11-704-A63P -- tre answer 4, page 12 Attachment C Drawings and calculations for support CC-2-011-706-A63R -- see answer 4, page 12 Attachment D 8/17/84 letter from B. J. Youngblood, Chief, Licensing Branch 1*n. 1, Division of Licen?!nC, NRC, Washington, to M. D. spence, President, TUGC0 -- see answer 5, page 16 19 1
="
The preceding CASE's Answer to Applicants' Statement of Material Facts As To Which There Is No Genuine Issue was prepared jointly under the personal direction of the undersigned, CASE Witnesseshek Doyle and Mar'h hish]WecanbecontactedthroughCASEPresident.hs.JuanitaEllis,1426 S. Polk, Dallas, Texas 75224,214/946-9446] Our qualifications and background are already a part of the record in these proceedings. (SeeCASEExhibit842,RevisionthsumeofJackDoyle acceptedintoevidenceatTr.7042,andCASEExhibit841,Fevisiontohsume ofMarkWalsh]acceptedintoevidenceatTr.7278;seealsoBoard's 12/28/83 Memorandum and Order (Quality Assurance for Design), pages 14-16.) We have read the statements therein, and they are true and correct to the best of our knowledge and belief. We do not consider that Applicants have, in their Motion for Summary Disposition, adequately responded to the issues raised by us; however, we have attempted to comply with the Licensing Board's directive to answer only the specific statements made by Applicants. i"
' Q gned) Mark Walsh /
STATE OF TEXAS On this, the ) day of O h C[44 [ , 1984, personally appearedhrkWalsh2knowntometo'befepersonwhosenameissubscribed to the foregoing instrument, and acknowledged to me that he executed the same for the purposes therein expressed. . Subscribed s'd sworn before me on the M-7 day of V 1934 evw.uo N b tary Public'in and for the State of Texas i My Commission Expires: I SAMUEL W. NESTOR My Commission E.xpires 13185
The preceding CASE's Answer to Applicants' Statement of Material Facts As To Which There Is No Genuine Issue was prepared jointly under the personal direction of the undersigned, CASE Witnesseshek Doyle and Mark) hish]WecanbecontactedthroughCASEPresident. hrs.JuanitaEllis,1426 S. Folk, Dallas, Texas 75224, 214/946-9446) Our qualifications and background are already a part of the record in these proceedings. (SeeCASEExhibit842,RevisiontohsumeofJackDoyle] acceptedintoevidenceatTr.7042,andCASEExhibit841,Revisioncohesu=e of Mark Walsh accepted into evidence at Tr. 7278; see also Board's 12/28/83 Memorandum and Order (Quality Assurance for Design), pages 14-16.) We have read the statements therein, and they are true and correct to the best of our knowledge and belief. We do not consider that Applicants have, in their Motion for Summary Disposition, adequately responded to the issues raised by us; however, we have attempted to comply with the 1.icensing Board's directive to answer only the specific statements made by Applicants. r.f .
?N' (Si ed) 'Jackpoyl'e /
Date: byA N /0$$ \ STATE OF M h ew b 'k COUNTY OF ki mk On this, the % 4( day of Pt.m , 1984, personally appeared ek J. Doyle] known to me to be0 he person whose name is t subscribe to the foregoing instrument, and acknowledged to me that he executed the same for the purposes therein expressed. i Subscribed and sworn before me on the $$b day of (L.tu oi , O 1984 b c_ S. L Notary Pub {ic in and for ihp g State of Wo-m h,TF, My Commission Expires: - MY COMMISSION EXPtRES JANUARY 9,19d7
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4t UNITED STATES 23g/
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AUG 17 1984 Occket No.: 50-445 ATTACEMER D - Mr. M. D. Spence President Texas Utilities Generating Company 400 N. Olive Street L. B. 81 Dallas, Texas 75201
Dear Mr. Spence:
Subject:
Acceptance of Preoperational Test Deferrals for Comanche Peak Steam Electric Station, Unit 1 The staff has completed its review of the following preoperational tests requested by letters dated May 29, June 5, June 8 and June 15, 1984 from B. R. Clements:
- 1. Containment Cooling Systems 4
- 2. Safety Injection System Check Valve Leakage
- 3. Turbine Drive Auxiliary Feedwater Pump Steam Supply Line Check Valve and Orain Pot Level Control Valve 4 Reactor Coolant Pump Seal Performance
- 5. Thermal Expansion Testing
- 6. Control Room Ventilation System Enclosed are the staff's evaluations which are the proposed findings for inclusion in a future SER supplement. These proposed findings indicate that the requested deferrals are acceptable. Therefore, the Unit 1 Oper-ating License will contain license conditions consistent with your commit-ments on conducting the tests prior to initial criticality.
t Sincerely, l gx u / 6d {i 8., J j oungbloo , Chief Lic nsing Branch No. 1 Division of Licensing
/.
Enclosure:
As stated ' cc: See next page 9
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The applicant will have corrected these deficiencies and prcposes that the test be repeated after fuel loading when the next plant heatup is completed for initial criticality. Final cold setting of retest items would be acccmplished at the shutdown scheduled at the end of the 30". power plateau. , The deferral of the thermal expansion retest is acceptable because it is consistent with approved industry practice on other plant test programs. Furthermore, compliance with Technical Specifications relating to piping supports will be required for plant operation to proceed. F. Control Room Ventilation System During performance of the Control Rocm Ventilation System preoperational test, it was deterinined that tre system provided more than adecuate air supply to the control room area for Unit 1, but less than design air flow was supplied to Unit 2 control room area. The applicant is proceeding with modifications to the ventilation system to correct the design deficiency. The applicant plans to start retesting the modified system, but anticipates not being able to cceplete the testing prior to scheduled Unit 1 fuel loading. The applicant, therefore, requests deferral of completion of the test until after fuel loading. Based on the condition that this deferral is a retest of a system which was already determined to be acceptable for the Unit I control area, we find the deferral of the retesting of the Control Room Ventilation System until completion of the initial fuel loading of Unit 1.(and before initial criticality) to be acceptable. In summary, the ceferral of these six preoperational tests represent retesting of modifications made to correct identifie'd system deficiencies in the respective systems. Retesting these systems after initial fuel loading, but prior to initial criticality, will pose no safety problem, will be controlled by the plant Technical Specifications and are consistent with other plant test programs. On this basis, the requested deferrals are approved.
_i,.=,. . COMANCHE PEAK SU6171334
~
Mr. M. D. Spence - President Texas Utilities Generating Company 400 N. Olive St., L.B. 81 Dallas, Texas 75201 cc: Nicholas S. Reynolds, Esq. Mr. James E. Cumins - Bishop, Liberman, Cook, Resident Inspector / Comanche Peak Purcell & Reynolds Nuclear Power Station 1200 Seventeenth Street, N. W. c/o U. S. Nuclear Regulatory Washington, D. C. 20036 Comission P. O. Box 38 Robert A. Woold-idge, Esq. Glen Rose, Texas 76043 Worsham, Forsythe, Sampels & Wooldridge Mr. John T. Collins 2001 Bryan Tower, Suite 2500 U. S. NRC, Region IV Dallas, Texas 75201 611 Ryan Plaza Drive Suite 1000 Mr. Homer C. Schmidt Arlington, Texas 76011 Manager - Nuclear Services Texas Utilities Generating Company Mr. Lanny Alan Sinkin Skyway Tower 114 W. 7th, Suite 220 400 North Olive Street Austin, Texas 78701 L . B . 81 Dalla's, Texas 75231 , B. R. Clements Vice President Nuclear Mr. H. R. Rock Texas Utilities Generating Company Gibbs and Hill, Inc. Skyway Tower 393 Seventh Avenue 400 North Olive Street New York, New York 10001 L . B . 81 Dallas, Texas 75201 Mr. A. T. Parker Westinghouse Electric Corporation William A. Burchette, Esq. P. O. Box 355 1200 New Hampshire Avenue, N. W. Pittsburgh, Pennsylvania 15230 Suite 420 Renea Hicks, Esq. i Assistant Attorney General Ms. Billie Pirner Garde ! Environmental Protection Division Citizens Clinic Director P. O. Box 12548, Ca,,itol Station Government Accountability Project Austin, Texas 7S711 1901 Que Street, N. W. l Mrs. Juanita Ellis, President i Citizens Association for Sound David R. Pigott, Esq. Er.svgy Orrick, Herrington & Sutcliffe 1426 South Polk 600 Montgomery Street Dallas, Texas 75224 San Francisco, California 94111 Ms. Nancy F. Williairs Anthor.y Z. Roisman, Esq. CYGNA Trial Lawyers for Public Justice 101 California Street 2000 P. Street. N. W. San Francisco, C611fornia 94111 Suite 611 Washingte'n, D. C. 20035 l l ! *7 i
. s . ~, o . ~
ENCLOSURE SUPPLEl1 ENTAL SAFETY EVALUATION REPORT DEFERRAL OF CERTAIN PREOPERATIONAL TESTS COMANCHE PEAK UNIT 1 Texas Utilities Generating Company in letters from B. R. Clements to H. R. Denton, NRC, dated flay 29, June 5, June 8 and June 15, 1984', requested approval to defer six preoperational tests until after fuel loading. The testing would be completed prior to initial criticality with the exception of a portion of the thermal expansion test. This test requires heatup and return to cold sh.?.down conditions for ccmpletion and is scheduled at the completion of the 30 percent pcwer plateau. A. ICP-PT-45-06, Containment Coolinc Systems The applicant has requested that this test be repeated after fuel loading. Testing of the containment cooling systems were performed during'the normal preoperational test program; hcwever, test oeficiencies were identified requiring system modifications which could not be retested prior to the scheduled fuel loading. 1 The repeat of this test after fuel loading is acceptable because only limited portiens of the system require retesting, no technical j specification exceptions are required and, for operation to continue, the system must still meet technical specifications temperature limits in critical areas. B. '1CP-PT-57-09, Check Valve and Hot Functional Safety Injection The applicant has requested that this test be repeated after fuel loading. During the initial test, a number of check valves leaked in excess of their acceptance criteria. These valves have been repaired or replaced. The repeat testing of these valves wculd be ' performed as j
/
required by the technical specifications surveillance tests for check valves. It is acceptable to defer repeating portions of this test until j after fuel loading, but before criticality, because (1) it is consistent with the technical specifications which control normal operation and
- define check valve operability and (2) presents ne safety problem because retesting is completed prior to critic'ality.
~
4 .D # . M k'T4W,- soevers ' - 101 Cahfornia street, sete 1000 san Francisco. CA 941115894 415 397 5600 August 25, 1984 - nnCEC E - 84042.016 Mr. J. B. George Project General Manager Tsxas Utilities Generating Company Comanche Peak Steam Electric Station Highway FM 201 Glen Rose, Texas 76043
Subject:
Phase 3 Open Items - Mass Participatior. Comanche Peak Steam Electric Station Independent Assessment Program - Phase 3 Job No. 84042
References:
a) R. E. Ballard (Gibbs & Hill) letter to J. B. George (TUGCO),
" Revised Hass Participation Fraction Sensitivity Study," GTN-69316, August 3, 1984 b) R. E. Ballard (Gibbs & Hill) letter to J. B. George (TUGCO), "G&H Followup Activities for Cygna (Phase 3)," GTN-69279, July 20, 1984
Dear Mr. George:
Cygna has reviewed the reference (a) letter regarding a revision to the Gibbs & Hill mass participation study. Since we have not yet received the Gibbs & Hill preliminary report on the results of the revised ADLPIPE analysis (see reference b), our reviewers are unable to fully understand the reasonableness of approaching the analysis in the manner proposed. A Cygna reviewer is scheduled to visit the Gibbs & Hill offices on Argust 28, 1984 in order to review the work p2rformed to date. In the interiot, Cygna believes it is necessary to notify TUGC0 of the following concerns regarding the use of this revised approach: G The method proposed by Gibbs & Hill uses the high?r of the loads from the static ZPA analysis and the loads from the dynamic analyses. This
" yardstick" for determining support adequacy may be considered inadequate since this criteria does not satisfy the requirements of the 4 CPSES FSAR Section 3.7B.3.1, which specifically states that: "The 7 number of modes chosen is considered adequate provided that inclusion .? of additional modes does not result in more than a 10% increase in 4 responses, or based upon evaluation of the dynarnic participation factors to assure that all significant modes have been included."
Checking that the support loads in a system . equal the mass multiplied by the ZPA is a good review too! to determine the reasonableness of a dynamic analysis. If it is to be used for design purposes a study must s2n Francisco Boston san Diego cmcago Ricman'a
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. 1 849419 n, E~hu [42^"/ Y e
S e ,,, fo hWj' UNITED STATES OF AMERIfA NUCLEAR REGULATORf COMMISSION BEFORE THE ATCMIC SAFETY AND LICE!;3"M2DF'] In the Matter of 1 I - l 00,cket Nos. EO 345-? TEXAS UTILITIES GENERATING and 50 446 1 CCMFANY, et al. l I . (Comanche Peak Steam Electric Station l Station, Units 1 and 2) j CASE'S PARTIAL ANS'4ER TO APPLICANT'i' STATEMEN:: OF tiAT5 RIAL FACTS AS TO VHICR It4ERE IS No CD'UIYF. ISSUE REGARDING DIFFEPINTIAL DISFLACEtiENT OF LARGE-FPJ01ED, VAL'-TO-kAI L AND FLOOR'TC-CEILING PIPE _S g oJ.Ts , in the form of AFFIDAVI?0FCASEWITNESShRRWALSH G k It should be noted at the outset that Applicents sta:e that the Affidavit addresses the Licensing 3oard's 'questionr, (see discussion cn paste 2 of the Iotti/Finneran Af tidavith Hossver, I ghallenge that stat eewnt. In order for Applicants to hwe adequately resolved the Ecard's questions, they should have included documentation of their claims. They did not. There is not one drawing, not one calculation, tot one regularly used s.ite document attached to their Affidavit, in addition, Applicants have- not adequately answeed the Board's questions. On page 6 of Applicents Affidavit, Applicants attempt t.o sasser the Board's first question, "how it care about that PSE violated its twn design guidelines." As will be shown in the ans~wers herein, the PSE Group FDA-60-os c@b Y , j m
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~
In . did not have guidelines when these supporth were ot'iginally designed. addition, it is a code raquitecent to consider the effects of this type of This is support c'ontigurntjo6, as y[11 be shovn in t'he answers berein. contrary P.o the stateme..st provided in the Af fidavit. Os page 7.of the Aff'dsvit, i Applicants attempt to answer the Koerd's seccod qu'estion, "bov did this event (come) to be reflected in the design qualjty assuran:e syste'a?" The reepouse provided by the Applicants is a be.ch i of balbnefi. As will be shown herein, CC does not interface with , derign. On page 7 of tte Af fidavit, Applicants attempt to ensver the Board's As thicd question, "whether this problem received prcmpt Attention." indicated herein, the Applicanth informed the NRC Speciel Inspection Team (31T) t?.ac.these supports vert unable te withstand differential seismic This rodesign and modification dispiacasen'es and were being redesigned. occurred ow! yest aftkr the Applicants claimed they knew of the problem. to This it not prompe. It cely belane prompt af ter Jack Doy~ a and I went the Licenring Board.
- 1. Appli.cahts state:
"In late 1981 Applicants identified four floot-to-ceiling suoporte designed by P?E without slip joints as being incensistent with PSE guidelines. The PSA guidelines ses.te that such large-framed supports shoele have slip-joints, the perpCse bei6g to negate the need to n l
analyze different.ial displacenents of the supports between elbor a,d ceiling or between valls. Affidavit at p. 3 " , The Applicants did not state which fcur suoports ,thev identified And more as not b.eing consistent sith the PSE Cuidelines. d 4 2 D m
s . specifically, when in late 1981 did they find these? The specific date isimportantsincetherewerenoPSEguidelinespriortolate1981f1/. Since the PSE identified these problems in late 1981 and the supports had already been designed and constructed prior to that, these supports had been designed and constructed without any documented guidelines to follow, including which code was to be utilized.
- 2. Applicants state:
"The four supports were conservatively designed such that the floor-to-ceiling columns could simply be cut of f and the support would still be adequate. H. at p. 4."
Applicants did not provide copies of the support calculations or Therefore, drawings with their Motion to substantiate this statement. I cannot agree. Further, Applicants are trying to tell the Board that the "four the floor-tc-ceiling supports were conservatively designed such that columns could simply be cut off and the support would still be adequate." However, this is not what Applicants told the NRC Special Inspecticn Team (SIT). They told ebe SIT /2/:
"During the course of the inspection, the Applicant informed the Special Inspection Team that chase supports would be unable to withetand dif ferential seismic displacements and were beine redesiened." (Emphasis added.)
Statement cf
~))
f See discussion in CASE'e 8/13/84 Answer to Applicants' Material Facts As to Which There Is No Genuine Issue P.egarding CASE Allegations Pegarding Section Property Values, last paragraph on page J continued on page 4, and Footnote 2. and
/2/ See discussion in CASE's 8/22/83 Proposed Findings of Fact
~~
Conclusions of Law ([Walsh/Doyle} Allegations) (hereinaf ter referred to as CASE's Proposed Findings), page VI-l!. 3
~
i
9 This does not support Applicants' statement that the supports were , conservatively designed to begin with.
- 3. Applicants sta,te:
"To demonstrate the edequacy of the initial designs, using the computer I code STRUDL, one of the four identical supports was analyzed using conservative assumptions and tiie reJulting stresses in the support were all below allovsbles, Indeed, the actual dif ferential seismic displacement was calculated to be .006 inches; a' limited displacement of this magnitude would, as a practical reality, not be a concern for these supports. Id. at pp. 4-3.
There is no documentation to ecnfirm Applicants' statement at page 3 of their Affidavit that the four supports were identical. If they we ren' t , I don't know if they had evaluated the worst case; that is, being a member that was already close to allovables, one ylth maximum differential seismic displacements, concrete creep displacement ef fects, thermal loads, or local ef fects. Therefore, since this information was not provided, I cannot agree with the statements above for all supports. In any case, this is not what the Applicants told the SIT, as shown above in Answer 2. 4 Applicants state:
" Applicants have reviewed all Unit 1 and common safety related piping supports and determined that there are an (sic) 26 supports spanning from wall-to-wall or floor-to-ceiling. Of these 26 supports, seven have slip-joints, four have small spans and negligible movements and are not considered large-framed supports, and the remaining 15 have been evaluated and adequately consider the potential for differential seismic displacement. Id. pp. at 5-6."
4 B m
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y
Of the tuelve supports (the criginal four discovered in 1981 plus . the eight shown in Attachment 1 to Applicants' Affidavit) which are considered tu be a PSE design, only four (or 33%) meet the design criteria. F0e all the remaining supports, since I have not reviewed the documents (drawings a9d calenlations), I cannot agree with any of Applicants' conclusions.
- 5. Applicants state; "None of these remaining 15 supports were designed by PSE, and all were designed prior to the time that the PSE guideline was made applicable to the other design organizations. Id. at p. 6."
Applicants' statement above is completely contradictory to what The SIT stated (psge they told the NRC Special Inspection Team (SIT). 3 25 of SlT Report, NRC Staff Exhibit 207) f]/:
~
"Regarding the effect.s of differential seismic displacemeats, the Special Inspection Team verified that the PSE guidelines require that when large frames are necessary to span across a corridor or from floor-to-celling, one end connection must be designed as a slip joint. (Paragraphs 2 and 13, TUSI Engineering Guidelines, Section II). ITT-Grinnell and NPSI guidelines do not have a similar requirement. However, the Special Inspection Team was informed that neither of these pipe support design groups have In frames.
designed wall-to-vall or floor-to-ceiling support subsequent discussions the Applicant provided the Special 19, 1983 Inspection Team a copy of a memorandum dated January directing the recipients, specifically ITT-Grinnell and NPSI personnel, to use the same seismic guidelines as those contained in ene TUSI Engiceering Guidelines in the event they design these types of support frames." (Emphases added.) See_ also discussion in CASE's Proposed Findings, page VI-ll. 23/ 5 y @
1
\
b - 1 J l 1 s I
- 6. Applicants crate:
"The FSE guideline tegsrding f'ipor-to* ceiling and wall-to-wall supports is not a cods or procadotal isquirement, but 25ther guidance fee the designer. Is.
J at p. 6." This is not the implication Appliccats gave the . SIT (see quote in answee 5 abore, first sentenec). In addition, a requirement of she ASME Code not considered by Applicasts in to censider all possit'le loadings, including seismic displa saents, as set forth in ,4S:!E NF 3111(d throogh f) (sea CA$E Exhibit 659B, Attactment to 7/82 Te,stimony of Mark Walsh);
"NF-3111 Loading Ccaditions "The loadinge as specified in the besign Specifications (NA-3200) that shall be taken into adcount in designing a componen suppo'e r include, but are nor limit 4d to, the follcwing: .
". . . (d) Dynamic loads, inclu. ing d loads caused by sarthauske and vibration;
"(e) Restrained thermal expansicn;
"(f) Anchor and support movement ef fects . . ."
(Emphasis added.) Although not included in the ASME section referenced above, l cone:ete creep displacements should have been incl:ded in the originel calculations but were not shown in Applicants' Motion for Summarf Dispcsition. There is no documentatior. to indicate that aov cf these I effects have been considered. The imcortance of these items it discussed in detail in CASE's 8/22/83 Proposed Findings, Sectico VI, Further, Applicants have offeted no explanation as to why these supports were improperly designed to begin with. Cn pAge 6, they state that the individuals who were the designer and the reviewer are no l 1 - 6 l \
, ~ -
= - . . . . . - - .
. i longer employed at CPSESA however, they do not state that these ,
incividuale had alreadf left the site at the time Applic. ants discovered tnia problam in late 1981 There ir, nothing to indicate that Appitesnts attebpted to find cut in late 1981 why these individuals did not follov the asideline for these four PSE supports.
- 7. Applicants state:
"The failare to f ollow he t FSE Auldeline for these four supports did If not faquire the generdtion of aay -QC ncn-conformance documentation.
the supports had not been ad6auately designed, in the 7." first instance, cetvect.tve action would have bece requ(ted. Id at p. It is highly uniikely that GC would ever have known anything about Applicants' this probles, since th6y have ne contact with Engineering.
'Jitness Carv Krishnan (Si'ce Stress Analy. sis Group $9 pervisor and my forser imn3 diste supsrvisor), during his 7/10/84 deposition in the intimidation portion of the proce; dings, discussed how his group fits ,
13rd the engineertug argan,tzecion (Tr. 41,005/17-42,006/.!8 .and 41,000/22-42,014/11). And at Tr. 42,006/19-34, he stated:
"Q: In your position, do y6u h. ave concac: With any QA-0C ,
(,,spectort? ' "A: No, I do n4t.
"Q: Do QA-0C inspect 9rs judge the design abill.ty judged by the l FAG or STUDL (s(c) groups?
l "A: Nc." l For this reason, Applicants' statement is nesninglass, misleading, l i and deceptive. l ( ! o , 7
- ,,g
9
- 8. Applicants state:
"Because there was a design change of the four supports, the OA program Id,. at required generation of appropt.iste desigre change documentation.
- p. 7."
This statement is misleading, because it implies that this problem was all properly taken care of under Applicants' QA/QC program. However, both Jack Doyl and I were having to analyze supports of this kind ,as though they were all right, and complaining about it , in mid-to the Licensing Board that Applicants 1982. It v$s not until we went did anything about the probles. 9 Applicants state:
"The siisale deflection that could occur on wall-to-slab (ceiling or 4
floor) supports consis;s of vertical deflectionIn that such of_supports the slabare and near the herirontal deflection of the wall. the juncturs of the slab and wall, the actual deflection realized at support would be niulmal and less than the maximum 8."deflection realized Id. at p. toward ths middle of the wall or slab. 1 agree with the first sentence. I disagree with the cecond sentence, in particular the term
" minimal," To meet the seismic requ.irements, Comanche Feak instituted I a rigid type of framework, which results in minimal deflec tions but large seismic loads. When a sapport goes from floor-to-ceiling or wall-to-wall, the support meuber intercepts this 1.oad from the vall or floor-to-ceiling and acts as a structural boilding member and receives the 1 cad as if it were a building column.
W 8 M , _.
-- -- ,,, y - g ---a , , -.m i -- + t w T V ' -
t .
- 10. Applicants state:
"To determine if differential seismic deflection appeared to be a problem with wall-to-slab supports, Applicants analyzed three '
l i The representative supports using a computer code, STRUDL. differencial seismic displacement calculated ranged from .00035 inches to .0045 inches, which, as a practical reality, would not be a concern to any such supports. In any event, the results of the computer analyses reflects (sic) that stresses for all members are within allowables. Ijf. at pp. 8-9." Again, Applicants did not include any documentation to support their claims. For example, there is no indication of the methodology used to determine which supports were " representative." There were no I STRUDLrunsincluded(althoughbothf,ackDoylk}andIareveryfamiliar STRUDL). I therefore cannot agree with their statements. In addition, as discussed herein, Applicants have failed to adequately answer the three questions set forth in the Board's 2/8/84 Memorandum and Order at.p. 30 (see Applicants' Affidavit, page 2). Also, I have not had time even to scan the transcript of the 8/6/84 Applicants /NRC Staff / CASE telephone conference call (although I was on the call, there were some statements made which might be helpful), the transcripts of the 8/8/84 and 8/9/84 Bethesda meetings between the NRC Staf f and the Applicants (all of which were just received by CASE on 8/22/84), and i of course, the transcript of the meeting held at Comanche Peak 8/23/84 f between the NRC Staff and the Applicants. Also, it is my understanding that there will be some changes (at least one substantive) to some of Applicants' Af fidavits regarding some of the Motions for Summary Disposition and that by l 8/30/84 the Applicants are to provide the Staff with several documents
'9
. l j
relating to Motions for Summary Disposition (which obviously we also need to adequately answer Applicants' Motions). I would have liked to be able to do a more thorough job, and would like to be able to supplement my testimony after I have had a chance to review the referenced transcripts, changad Affidavits, and additional documents. v
~
10
The preceding CASE's Answer to Applicants' Statement of Material Facts As To Which There Is No Genuine Issue was prepared under the personal direction of the undersigned, CASE Witness rk Walsb] I can be contacted throughCASEPresidenthrs.JuanitaEllis,1426S. Polk, Dallas, Texas 75224,214/946-9446] My qualifications and background are already a part of the record in (See CASE Exhibit 841, Revision to Resume of ark Walsh these proceedings. accepted into evidence at Tr. 7278; see also Board's 12/28/83 Memorandum and Order (Quality Assurance for Design), pages 14-16.) to I have read the statements therein, and they are true and correct the best of my knowledge and belief. I do not consider that Applicants have, in their Motion for Summary Disposition, adequately responded to the issuesraisedbyCASEWitnesshkDoyle]andme;however,Ihaveattempted to comply with the Licensing Board's directive to answer only the specific statements made by Applicants. (Signed) Mark Walsh j l - -- STATE OF TEXAS day of 6M4 G 1984, personally On this, the 27 , appearedhrkWalsh]knowntometobethefpersonwhosenseeissubscribed and acknowledged to me that he ._xecuted the to the foregoing instrulant, same for the purposes therein expressed.
.2 7 day of W ,
Subscribed and sworn before me on the 1984 2 Weary Public in and Tor the
- SAMUEL W. StfifB of Texas - My Ccmmission Expires 13185 My Commission Expires:
. 849u22 ,
,heb da
$h S E (CITIZENS ASSN. FOR SOUND ENERGY) 1h26 8. Polk Sco Dallas, Texas 21h/946-9hh6 7522 o
97 August 29, 1984 (, Administrative Judge Peter B. Bloch Dr. Kenneth A. McCollom, Dean U. S. Nuclear Regulatory Commission Division of Engineering, Architecture 4350 East / West Highway, 4th Floor and Technology Bethesda, Maryland 20014 Oklahoma State University Stillwater, Oklahoma 74074 Or. Walter H. Jordan 881 W. Outer Drive i Oak Ridge, Tennessee 37830 Gentlemen:
SUBJECT:
In the Matter of Application of Texas Utilities Generating Company, et al . for An Operating License for Comanche Peak Steam Electric Station Units #1 and #2 (CPSES) Docket Nos. 50-445 and 50-446 CASE's Partial Answer to Applicants' Motions for Summary Disposition We are attaching CASE's Answers to the following Motions for Summary Disposition, in accordance with the Board's directives: Regarding Consideration of Local Displacements and Stresses Regarding Differential Displacement of Large-Framed, Wall-to-Wall and Floor-to-Ceiling Pipe Supports Regarding Allegations Concerning Consideration of Force Distribution in Axial Restraints Regarding the Upper Lateral Restraint Beam Regarding Applicants' Use of Generic Stiffnesses Instead of Actual Stiffnesses in Piping Analysis Regarding Safety Factors As indicated in these Answers, bothbMessrs. Walsh and Doyl,e]do not feel that they have been able to do an adequate job due to the severe time restrictions under which they have had to work. Likewise, I have been unable to do an adequate job either, and am dispensing with the usual cover letter because I simply do not have time to get them done. I assume that the Board approves of this procedure, under the circumstances. If not, please advise. As also indicated,bssrs. Walsh and Doyle)would like the opportunity to supplement their answers, where appropriate, when new information is received. p r;f gj[go F01A-8b e
I hope the Board understands that I sincerely mean no disrespect by what I am about to say. I am merely reporting the current situation with CASE, our witnesses, and me. If the Board is interested in seeing just how much flesh and blood can endure without total collapse, please consider that. that limit has been reached and exceeded. The attached si Answers are the result of superhuman effort on the part of all of us, and . Doyle, Mr. Walsj) and I have all reached the absolute limits of phys 1 and mental endurance (at least for the time being, until we have had a little time to regenerate our: elves). One cannot keep going steadily for 14 to 16 hours a day, seven days a week, day-in and day-out, for weeks on end -- as we have been forced to do to meet the Board's deadlines
-- (which is far more than the Board requires of the NRC Staff with its nL.aerous attorneys, witnesses, consultants, typists, secretaries, etc.) without its taking its toll.
We will attempt to meet the Board's deadlines for as long as possible. I have too much to do to continue to file Motions for Reconsideration asking for more time (never knowing whether or not they will be successful). At this point, I am not at all certain that I will physically be able to meet the deadline the Board has set for the welding findings. I have had to make a difficult choice -- the Answers to Motions for Sunnary Disposition or the welding findings. I have not been able to work on the welding findings for any length of time. Although we do have a few CASE volunteers who are helping with them, there is no one else in our organization who has the back-ground to be able to pull the.. all together in a logical, orderly fashion for the Board except me. I'll do what I can. As usual, what can't be done won't be. And the record will suffer. There is one other matter to which I want to call the Board's attention. Contrary to what was stated by Appl! cants' counsel during the telephone con-versation between the Board Chairman, Applicants' counsel, and me on Monday, 8/27/84, it is my understanding from further conversations with Dr. and Ms. Boltz (who attended the 8/23/84 meeting on behalf of CASE) that there is to be a substantive change in at least one Affidavit, regarding Richmord Inserts, and the Applicants' Motion for Summary Disposition. We ask that the Board check with the Staff and Applicants to ascertain whether or not this is true. If it is, CASE strongly objects to having to answer this Motion without having this change and any accompanying documents in hand, and sufficient time to properly review and analyze them. Our answer is currently scheduled to be put in t e mail on 9/10/84. We will appreciate the Board's assistance on this. Sincerely, CASE (Citizens Association for Sound Energy) r %
~Na nt b.Ww iMrs.) Juanita Ellis, President cc: Service List u m ~
Attachments
?
e C A S E (CITIZENS ASSN. FOR SOUND
== -
AugustENERGY) 29, 1984 Docketing and Service Section Office of the Secretary V 5. Nuclear Regulatory Commission Washington, D. C. 20555
Dear Sir:
Sutject: In the Matter of Application of Texas Utilities Electric Company, et al. for An Ooerating License for Comancne Peak Steam Electric Station Units #1 and #2 (CPSES) Docket Nos. 50-445 and 50-446 CASE's Partial Answers to Applicants' Motions for Summary Disposition are attaching the original signed and notarized Affidavits ofkrk Wals)h and ck Doyle which are attached to CASE's 8/29/84 letter to the LicensingTaard attaching] CASE's Partial Answers to Applicants' Statement of Material Facts As To Which There Is No Genuine Issue Regarding the specific items listed below: Consideration of Local Displacements and Stresses --[ Jack Doylh Differential Displacement of La e-Framed, Wall-to-Wall and Floor-to-Ceiling Pipe Supporcs - g k Wals Respectfully submitted, (continued below) CASE (Citizens Association for Sound. Energy) F r .
~
. MM- w J[rs.) Juanita Ellis President cc: Service List Attacnment Allegati ns Concerning Consideration of Force Distribution in Axial Restraints
-- k Walsh Upper L eralRest)raintBeam-- ack Do le and Mark Wal Applicants' Use of Generic Stif sses nstead of Actua Stiffnesses -- both Safety Factors - botn 50 Mt f6t " 3f/
.e .
l l l i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION f BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of }{
}{
TEXAS UTILITIES ELECTRIC }{ Docket Nos. 50-445-1 COMPANY, et al. }{ and 50-446-1 (Comanche Peak Steam Electric }{ Station, Units 1 and 2) }{ CERTlFICATE OF SERVICE By my signature below I CASE's Partial Answers to Applica,ts,hereby n Motions certify that trye for Summary and gorrect 01sposition cooies Consideration Regarding: of of Local Displacements and Stresses; Differential Displacement of Large-Framed, Wall-to-Wall and Floor-to-Ceiiing Pipe supports, t.onsiceration of i orce vistrioution in Axiai iies craincs, Upper
> Lateral Restraint Beam; Use of Generic Stiffnesses Instead of Actual Stiffnesses in Piping
, Analysis; ano sarety ractors , have been sent to the names listed below this 28th day of Augus t ,198{, by: Express Mail where indicated by
- and First Class Mail elsewhere.
- Administrative Judge Peter B. Bloch
- Nicholas S. Reynolds, Esq.
U. S. Nuclear Regulatory Commission Bishop, Liberman, Cook, Purcell 4350 East / West Highway, 4th Floor & Reynolds Bethesda, Maryland 20814 1200 - 17th St., N. W. Washington, D.C. 20036
- Ms. Ellen Ginsberg, Law Clerk U. S. Nuclear Regulatory Commission
- Geary S. Mizuno, Esq.
4350 East / West Highway, 4th Floor Office of Executive Legal l Bethesda, Maryland 20814 Director U. S. Nuclear Regulatory
- Dr. Kenneth A. McCollom, Dean Commission Division of Engineering, Maryland National Bank Bldg.
Architecture and Technology - Room 10105 Oklahoma State University 7735 Old Georgetown Road l '
- Stillwater, Oklahoma 74074 Bethesda, Maryland 20814 h Chairman, Atomic Safety and Licensing
- Dr. Walter H. Jordan 881 W. Outer Drive Board Panel l, Oak Ridge, Tennessee 37830 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 l
I. 1
Chairman Renea Hicks, Esq. . Atomic Safety and Licensing Appeal Assistant Attorney General Board Panel Environmental Protection Division U. S. Nuclear Regulatory Commission Supreme Court Building Washington, D. C. 20555 Austin, Texas 78711 John Colline Regional Administrator, Region IV U. S. Nuclear Regulatory Conmission 611 Ryan Plaza Dr., Suite 1000 Arlington, Texas 76011 Lanny A. Sinkin 114 W. 7th, Suite 220 Austin, Texas 78701 Dr. David H. Boltz 2012 S. Polk Dallas, Texas 75224 Michael D. Spence, President Texas Utilities Generating Company Skyway Tower 400 North Olive St., L.B. 81 Dallas, Texas 75201 Docketing and Service Section (3 copies) Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D. C. 20555
= 9
$d d - w_ - e <
,(Mrs.) Juanita Ellis, President CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 l 2
g~. d
,.d h 1h26 8. P:1k Dallas, T,xas 7522h d.
21h/9k6-9hh6 ( CITIZENS ASSN. FOR SOUND ENE.RGY) September lo, 1984 Administrative dudge Peter B. Bloch Dr. Kenneth A. McCollom, Dean U. S. Nuclear Regulatory Comnission Division of Engineering, Architecture 4350 East / West Highway, 4th Floor and Technology . Bethesda , Mar'yland 20014 Oklahoma State University Stillwater, Oklahoma 74074 Or. 'elalter H. Jordan ' 881 W. Outer Drive Oak Ridge, Tennessee 37830 Gentlemen:
SUBJECT:
In the Matter of Application of Texas Utilities Generating Company, et al . for. An Operating License for Comanche Peak Steam Electric Station Units #1 and #2 (CPSES) Docket Nos. 50-445 and 50-446 CASE's Answer to Applicants' Motion for Summary Disposition Regarding Richmond Inserts Fursuant to the Board's order during the last conference call, we are attaching herewith subject Answer. g.WalsQoptedtogoaheadandfileanAnswernow with the understanding that we would be allcwed to file a supplementary response upon receipt of the documents which Applicants were to have provided to the NRC Staff by 8/30/84 (allowing time to review and analyze them) ,rather than accept the other alternative of receiving an additional 5 days with no guarantee that we would be allowed to supplement our response. {Mr.Walsh' signed affidavit will be sent under separate cover, since he was ITct able to get it notarized in time to get this Answer of f in the mail. In addition, CASE Attachment D will be sent at that time, because I simply was unable to complete typing it from the rough draft (which is complete) and get i this mailing out too. I trust that this will meet with the Board 's approval, especially'since . Wals relies upon it in his Affidavit (which is CASE 's Answer) . ., I regret that I will be unable to attend any of the Intimidation hearings, due to the heavy work load currently being experienced. Perhaps one day I'll be able to read the transcripts and find out what Applicants ', Staf f 's , and CASE's own witnesses had to say. I will, however, never be able to forget the feeling that I have let our witnesses down by not at least being available to lend them moral support during their inquisition depositions. Respectfully submitted,
" " CASE (Citizens Association for Sound Energy)
I >$dri ^VV s ' cc: Service List Ms.) Juanita Ellis, President I y ,
I l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Maiter of }{
}{
TEXAS UTILITIES ELECTRIC }{ Docket Nos. 50-445-1 COMPANY, et al. }{ and 50-446-1 (Comanche Peak Steam Electric }{ Station, Units 1 and 2) }{ CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of CASE's Answer to Applicants' Motion for Summary Disposition Regarding Richmond Inserts have been sent to the names listed below this loth day of September,198;4, _ by: Lyngp3xhil where indicated by
- and First Class Mail elsewhere.
Federal Express
- Administrative Judge Peter B. Bloch
- Nicholas S. Reynolds, Esq.
U. S. Nuclear Regulatory Commission Bishop, Liberman, Cook, Purcell 4350 East / West Highway, 4th Floor & Reynolds Bethesda, Maryland 20814 1200 - 17th St., N. W. Washington, D.C. 20036
- Ms. Ellen Ginsberg, Law Clerk U. S. Nuclear Regulatory Commission
- Geary S. Mizeno, Esq.
4350 East / West Highway, 4th Floor Office of Executive Legal Bethesda, Maryland 20814 Director U. S. Nuclear Regulatory
- Dr. Kenneth A. McCollom, Dean Commis sion Division of Engineering, Maryland National Bank Bldg.
Architecture and Technology - Room 10105 Oklahoma State University 7735 Old Georgetown Road Stillwater, Oklahoma 74074 Bethesda, Maryland 20814
- Dr. Walter H. Jordan Chairman, Atomic Safety and Licensing 881 W. Outer Drive Board Panel Oak Ridge, Tennessee 37830 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 1
I
l Chairman Renea Hicks, Esq. ) Atomic Safety and Licensing Appeal Assistant Attorney General l Board Panel Environmental Protection Division U. E. Nuclear Regulatory Commission Supreme Court Building Wcshington, D. C. 20555 Austin, Texas 78711 John Collins - Regional' Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Dr., Suite 1000 Arlington, Texas 76011 Lanny A. Sinkin 114 W. 7th, Suite 220 Austin, Texas 78701 s Dr. David H. Boltz 2012 S. Polk Dallas, Texas 75224 Michael D. Spence, President Texas Utilitiet Generating Company Skyway Tower 400 North Olive St., L.B. 81 Dallas, Texas 75201 Docketing and Service Section (3 copies) Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Os L . > h/1 ' (yys'.)'Juanita Ellis, President CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 _J r 2
~ ~
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of l . j TEXAS UTILITIES GENERATING l Docket Nos. 50-445-1 COMPANY, et al. i and 50-446-1 (Comanche Peak Steam Electric Station l Station, Units 1 and 2) l CASE'S ANSWER TO APPLICANTS' STATEMENT OF MATERIAL FACTS RELATING TO RICHMOND INSERTS AS TO WHICH THERE ARE NO MATERIAL ISSUES in the form of AFFIDAVIT OF CASE WITNESS MARK WALSH ~ L --
- 1. Applicants state:
" CASE has raised six allegations concerning Richmond inserts. These allegations relate to (1) the factor of safety used for Richmond inserts, (2) testing of Richmond inserts, (3) the ability of Richmond inserts to resist axial torsion, (4) methods used to analyze connections, (5) bending moments in the bolts, and (6) sharing of shear loads. Affidavit of John C. Finneran, Jr., Robert C. Iotti and R.
Peter Deubler, Regarding Design of Richmond Inserts and Their Application To Support Design (' Affidavit') at 2-3." AshashappenedbeforeinApplicants'StatementofhaterialFacts As To Which There Is No Cenuine Issue, the statement contained in ! allegedly Material Fact 1 is misleading, because it gives the erroneous impression that CASE has raised only six allegations concerning Richmond inserts. It should be noted that this is not the same impression conveyed by the sworn statement of Applicants' witnesses at Affidavit page 2, which states: "niis Affidavit responds to six CASE
" CASE's concerns regarding Richmond inserts are allegations . ..
1 yh j 1 V
discussed in Sections VII cnd VIII of CASE's 8/22/83 Proposed Findings of Fact and Conclusions of Law (Walsh/Doyle Allegations). Applicants' representation of CASE's allegations is correct as far as it goes, but it it simplistic and incomplete, as a review of Section VII and VIII of CASE's Proposed Findings plainly indicates. Such a review plainly demonstrates that Applicants' Motion for Summary Disposition does not adequately answer all of CASE's allegations. Just a few of many specific problem areas and allegations which were also included in CASE's Proposed Findings (in addition to the specific allegations identified by Applicants in their statements) are as follow: (1) Distribution of shear to total bolt pattern as if all bolts were effective immediately; (2) Distribution of shear to the bolt without regard to the actual contribution of the upper and lower tube flanges; (3) Disregard of the bolt stiffness factor as contributing to the overall stiffness at the node point; (4) Improper method for coupling out the torsion in the tube; and checking LOCA scismic due to the structure on the basis of independent analysis uncoupled from other concurrent loads; (5) Applicable regulatory standards; (6) Thermal expansion effects, tension and shear due to expansion plus tension and shear from normal operation; 2 6
)
(7) The results of Applicants' applying ACI-349-80, " Code Requirements for Nuclear Safety Related Concrete Structures' (not adopted by the NRC as a regulatory requirement, and which allows a~ factor of safety of two for concrete inserts) and all factors required woyid place Applicants in the position of being non-conservative by a wide margin in the design of Richmond inserts at Comanche Peak; (8) Applicants are required by law (10 CFR Part 50, Appendix A, Criterion 1) to utilize the ACI code requirements or an equivalent code, because the procedures adopted by the Applicants do not address the considerations which resulted in the non-adop'ted code; (9) Failure to adopt the procedures set forth in ACI-349-80 or an equivalent code places Applicants in the pocition of being in violation of 10 CFR 50.34 (2) Novel Design Features and (8) Identification of Structures, Systems or Compenents requiring research and development; ... etc., etc.
- 2. Applicants state:
"In the manufacturer's literature regarding Richmond inserts, based on testing, the manufacturer specified the ultimate loads associated with the various sized inserts. In addition, the manufacturer selected a factor of safety, and back-calculated the corresponding allowable loads, i.e., the ultimate load divided by :he safety factor is equal to the allowable load. This factor of safety and corresponding recommended allowable loads specified by the manufacturer apply only to the Richmond insert itself and not to the threaded rod (sometimes used 3
interchangeably with bolt) which may be procured separately. Allowables for the threaded rod are those set forth in appropriate Codes, e.jl, for A-36 threaded rod the allowed load in shear is 17.7 kips. Id,. at 4."
,I agree with Applicants' statements except where it discusses the ;
allowable load for the A36 threaded rod (with which I disagree), which will be discussed in answer 7.
- 3. Applicants state:
"In its (sic) design calculations, Applicants used higher allowable loads for the inserts than specified by the manufacturer. Accordingly, if the ultimate loads recommended by this manufacturer were applicable to Applicants' use of the inserts at CPSES, it could be viewed that Applicants had reduced the factor of safety recommended by the manufacturer. Id."
I agree with Applicants' statements except where it states "it could be viewed." The Applicants' position in regards to this factor of safety (i.e., that a factor of safety of 3 which is recommended by the manufacturer is not a requirement at Comanche Peak) and they prefer . to use a factor of safety of 2, as shown on page 19, (2) first sentence, of the SIT Report (NRC Staf f Exhibit 207) (see discussion at page VIII - 4 of CASE's Proposed Findings):
"The allowable Richmond anchor tension loads were established by the Applicant based on a factor of safety of two of the ultimate load as determined from tests (Reference 7) and/or a shear cone analysis made by the Applicant."
This statement made by the SIT team was not rebutted by the Applicants. Therefore, the Applicants have reduced the factor of 4
i l safety recommended by the manufacturer, without any warranted analysis at the time they initially reduced it, and without adequate technical basis at that time. Their rationale as to why this is not the case (Applicants' Affidavit at pages 4 and 5) is inadequate and debatable, as will be discussed later.
- 4. Applicants state:
"The current allowable recommended loads for the inserts by the Richmond Screw Anchor Co. are based on tests conducted at the Polytechnic Institute of Brooklyn in 1957. Id. at 5."
I agree with this statement, with the following reservation. Any implication that the values listed are utilized at Comanche Peak is unwarranted. The values listed are not utilized at Comanche Peak, and no original calculations or documentation has been submitted to allow the Applicants to deviate from the recommended allowables. In addition, during the 8/6/84 telephone conference call between Applicants /NRC Staff / CASE, I requested documentation that Richmond Screw Anchor Co. has a quality assurance program and that the inserts which are being produced now and being used at Comanche Peak are still a reflection of the tests that were performed in 1957 (Tr. 40 and 42; see further discussion at Tr. 40 through 45). Applicants refused to provide this information and argued that it had no bearing on whether i or not the statement in Applicants' pleading is true or correct. Therefore, any implication that Richmond does have a quality assurance I program and that the inserts which are being produced now and are being used at Comanche Peak are still a reflection of the tests that were performed in 1957 is unsubstantiated and should not be drawn. 5
- 5. Applicants state:
" Data from the manufacturer's tests reflect that failure in all shear tests and the 1-1/2 inch tension tests occurred due to failure of the anchor stud bolts, not failure of the inserts. Failure in the 1 inch tensjon test occurred due to failurs of the insert by concrete cone ;
pullout." /1/ The concrete used by Richmond had a lower ultimate strength than sometimes is used at Comanche Peak. Therefore, the allowables recommended by Richmond were appropriate for the original design. See discussion later regarding Applicants' testing in answer 8. I do not know what bolting material was used for the test by Richmond. It is not stated in the test report back in 1957 and Applicants have not stated that they know either. It could have been a high strength bolt, which is an important consideration, as will be discussed later.
- 6. Applicants state:
" Failure of the insert can generally be equated with failure in the concrete resulting in a cone of concrete being pulled out (' concrete cone pullout'.) Even if f ailure by internal damage of the insert occurs instead of concrete cone pullout, the load at which it occurs is essentially the same at which concrete cone pullout would occur. I d,.
at 5-6 and Attachment B." I cannot tell from Applicants' Table A on page 6 what is from the Richmond Bulletins and what is Applicants' opinion. For instance, 1 don't believe that the statement "xx Ultimate shear load was in excess of 27,000 lbs. , hence allowable could be 9.0 kips" was made by Richmond l Screw Co., but is only Applicants' opinion.
/1/ There is no reference back to the aworn Affidavit of Applicants' witnesses. However, a review of Applicant,s' Affidavit indicates that the proper reference should be page 5.
6 l ( l P
Reviewing Table A (page 6 of Applicants' Affidavit), it is l apparent that the Richmond Screw Anchor Co. came to believe that it should se longer accept a factor of safety less than 3.0. Richmond is in basiness to sell their inserts and it seems reasonable to assume that the higher the allowable, the more inserts they can sell because they have a larger capacity; at the same time, Richmond is liable for failures when the applied loads are less than the allowab,le. Therefcre, it is apparent that Richmond Screw Anchor Co. determined that they needed a higher factor of safety to offset the possibility of failures when a lower factor of safety w6s used. Using the higher factor of safety may have somewhat decreased a possible selling point for their product, but it also has lesser.ed the chances for a failure of their insert under applied' Loads. It should also be noted that part of Applicants' Statement of Material Fact is taken from a footnote (bottom of page 6, footrote 3), while at the same time, another very important statement contained in the main body of the Affidavit is not included (last paragraph, page 6, of Affidavit):
"From the foregoing, it can be seen that the failure modes of concern are either failure of the insert through concrete cone pullout or failure of the threaded rod or bolt used with the
, insert." (Emphasis added.)
l This is a vitally important (and misleading) omission, since the i I vast majority of threaded rods or bolts used with Richmond inserts at Comanche Peak are low strength A307 (or SA36) bolts. See also discussion later in this pleading regarding Applicants' tests and Attachment B (which is Applicants' 4/19/84 Test Report, Shear l 7 1 -
i and Tension Loading of Richmond Inserts,1 1/2-inch Type EC-fW and 1-inch Type EC-2W). .
- 7. Applicants state:
" Allowable loads and factors of safety concerning the threaded rods (bolts) used with the inserts are established by Code and adhered to by Applicants. 3. at 6-7."
I disagree with Applicants' statement. Their statement is correct to the extent that this is apparently the value they now use. During the 8/6/84 Applicants / Staff / CASE telephone conference call, included in documentation which I requested on discovery was documentation which showed the Applicants checked the capacity of the threaded rod or bolt (Tr. 45 and 46). Of the three calculations provided which were within the containment, where Applicants did calculate the bolt capacity, the bolt allowable used was 17.67 kips. (See Attachment A hereto, which was marked by Applicants as Item 5; the first page of this Item is for support MS-1-002-003-C72S.) On the second page of this Item, which is for support RC-1-162-004-C81K, a Class 1 support, it states (middle of page) that for an A307 bolt the allowable used was 17.67 kips. However, the value of 17.67 kips is the allowable shear at room temperature. The Applicants have neglected to consider the temperature effects on the threaded rod due to a LOCA. Such consideration is required by NRC Regulatory Guide 1.124 ( Attachment B hereto), which states, in part:
"In selecting the level of service limits for different loading combinations, the function of the .upported system must be taken into account. To ensure that systems whose normal function is to prevent or mitigate consequences of events associated with an emergency or faulted plant condition (e.g., the function of ECCS 8
during faulted plant conditions) will operate preperly regardless of plant condition, the Code level A or B service limits of Subsection NF (which are identical) or other justifiable limits
'provided by the Code should be used." (B.S. of Regulatory Guide)
, Thus, the value of 17.67 kips as used by Applicents is incorrect -
when applied to LOCA conditions. Further, the correct allowable load for the 1-1/2" A36 rod is not 17.67 kips within the containment as Applicants have claimed. The yield strength of SA36 material at 300 degrees F. (LOCA temperature) is 31.9 kai (ASME, Appendix I, Table I-13.1). CASE , Exhibit 834 (admitted at Tr. 6471) contains a cover TUGC0 Office Memorandum from R. M. Kissinger, Project Civil Engineer, to M. R. McBay, Engineering Manager, regarding the attachment to the cover Memorandum, Applicants' March 30, *.701 Test Report, Shear Tests on i Richmond 1-1/2 Inch Type EC-6W Inserts. The Applicants determined the allowable shear capacity of the bolt by the equation: fv = Fv A where Fv = .3 times the yield strength of the material A = cross-sectional aren For a 1-1/2" diameter bolt, the allowable shear capacity for an A36 rod would = .3 times 31.9 times 1. 767 - 16.9 kips, which is less j than the 17.67 kips which Applicants currently use. Furthermore, the Applicants compare the allowable value for an A307 bolting atterial for ASME and AISC. In their calculation for the A307 bolt designatCons. the Applicants useu a value of Fv v 10.0 ksi, and arcivci at 17.67 hips as i p 9
+-N_. -+__r-_j- .-e-w - - - + - -%__ .w-+s - -
%-- -,w
the allowable value. And this is the value that they have utilized in their calculations. But the correct value for Fv is i ksi, as shown in Table I-7.3 of ASME Appendix 1. Utilizing the correct value of 7 kei, o a the allowable shear capacity of the bolt is 12.4 kips. As ad:mitted by Applicants in their 3/30/84 TUCCO memorandum, "17.67 Kips is the CPSES allowable shear load for 1 1/2" diameter A307 bolts when used in Richmond Inserts." And Applicants have never used tha lower, correct allowsble shear capacity value of 12.4 kips. As stated at the hottom of page VIII - 8 of CASE's Proposed Findings, A36 rods and A307 bolts are the same and are used by Applicants interchangeably (see Attachment C hereto, CASE Exhibit 834, cover memorandum discussing A307 bolts, and pages 3 and 4 of Test Report discussing SA-36 threaded rods). In addition, there was a discussion during the August 8, 1984, Bethesda meeting between Applicants and the NRC Staff regarding SA-36. Although this discussion originated regarding U-bolts, it is applicable also to this matter and (as discussed in more detail later) was included as an open item by Applicants in the August 23, 1984, site meeting. From the 8/8/84 meeting transcript (pages 15 and 16):
"MR. 10TTI: . . . ASTM specifications give you certain limits.
Carbon can be a maximu:n of .26 percent. But, it could be as low as .04. Maganese (sic) can go as high as .8, and silicon, again, can be as high as .15. Anything in between can be construed to be 36 type material. In addition, there are ether impurities that are permissible. So, it is truly garbage material. I think that is one reason why very little data is available, when you test. You test this A36 with the next A'!6. I "MR. Fl.ECE (NRC): I don't know whether I would characterize that as garbage material or not. I think there is a problem with this particular non-headed bolt that it originally was formed under the l 10
' ~
- ~ --
A307 spec, aad then for under the A707 epec which_I would chsracterire more am a garbag.a spec and A36 for non headed bol*cs
'then he said for ancho' rages would have to be raqualified for A16, which has such more reqairements say or tensile tests or ehemical requirements that A307.
' "MR. 10TTI: Well, when I meant garbage. You are right, I shouldn't use that word. To ne the material has so much variabiliev. It is al&ost impossib1'2 to test on a globe.1 nanner to deteraire what it is goirg to tent abida. (sic). Eecaute you ,
would have to essentially test every chetical corposition.
"MR. TERAO: Why do you say this was mad; for A3Gl?
"MR. FINNERAN: A307 is .the base expact (sic) for bolts.
"?qt. TERAO: Not bolts, U-bolt vaaterial.
ME. FINNERAN: .. . A3G7 is the bas. e(pect (ric) *or bolts.
There is also the requirement, A307 for non-headed bcits which n'er.d upgraded (sic) to thu tensile and chentesi requirements of I A36. . .
"MR. TERAO: In either c&se, whether they were Formed (sic),1 suews I was thick (alc) in terms cf ch9 Richmoi.2 inserts also.
They have A36.
"MR. FINNERAM: 'lo . That is A36 rod that has been thteaded also.
"So, neither the notes in the Richman (sic) insirts er he (sic) U-bolee sta made to an A307 spec."
(Esphases added.' Ir. addition (baped ofs the f.otes taken by Dc. and Ms. Boltz et the 8/23/84 site meecirg betw(en .\pplicants and FRC Staf f, since we still i da not have a copy of the transcript), it appears that Applicants P]e,
- going to reanwiyze SA36, as well s 3 providiag much additional inforcation to the NRC Staf*. From Dr, a:A Ms. Boitz' note 3 (the quotes here are only to indicate the b* ginning ar.J end af th.e nc;es, not necessarily exact quotations of the individgnis involved):
"LR. 19TTI: 'de're supposed to be providing additional information to the Gtaff. (
t 11
\ . w; -
l
"(1) Details of 8 Richmond insert patterns. We don't have those yet. Our schedule is by end of next week (30th).
"(2) Have to have information on the validity of the finite stress bending analycis, why it was necessary for them to do finite analysis and where the stresses are .
calculatad. We believed that it was a shear stress not pure bending stress. One test was under torsion, one was under shear.
"(3) Sisulating .ss a cantilever and a gxided cantilever.
They have 2 studies, haven't given to Staff yet. Load
- predicted by the test is higher and ,therefore not all bending, that's why we used finite element analysis.
"KR. 7 AIR (NRC): Did yon rely on test load deflections?
"IO7TI: Yes, that's why we used finite element analysis.
If the NRC does not accept finite element analysis, then wg will have to reanalyze 12 supports. ;
"(4) Yave to give to Staff about steel. Yes, we used SA36, we have to reanalyze this. (See past transcript, re:
garbaga steel.)
"(5) Aament release. Soce tube steels have Mz unreleased.
Answer is that none of chose; Mz is always released. This affects their Affidavit, where we got the Mx monant mixed up with the Mz moment. This affects their Affidayit, where we got the Mx moment mixed up with the K: monsne. The people working on the Affidavit, they mistadg es tood. So we have to redo the Affidarit.
"(6) Provide prying action; have results on it but is unveviewed, tut haven't sh.own to NRC yet. Talking sh.ut -
tube sizes and prying f actors and prying forces. Lac transcript of previous meeting. ,
"ICOTI: ,Back to No. 1: On the info on 8 patterns; I have not done anything on it yet.
" FAIR: If we confirm the informstion (1) that it was never model)ed as flued, r.han your Affidavit makes unwarranted assueptions; your analyst confused Mx with Hz and it's .lorger than 20", it. reali:y it's 46*'. Was this study done in a genstic fashfen?
"IOTTI: We did it genericall,v en a supposed worst case.
"IPPOLITO (6RC): When ate these all due to thu NRC'l "IOffit tverything's due by August 30."
12
~
L_ _---2 _, _
\
\
"(1) Details of 8 Richmond insert patterns. We don't those yet. Our schedule is by end of next week (pave 30th). ,
"(2) Have to have information on the validity of the finite stress bending analysis, why it was necessary for them to do finite analysis and where the stresses are ;
calculated. We believed that it was a shear stress not pure bending stress. One test was under torsion, one was under shear.
"(3) Simulating as a cantilever and a guided cantilever.
They have 2 studies, haven't given to Staff yet. Load
- predicted by the test is higher and therefore not all bending, that's why we used finite element analysis. j "MR. FAIR (NRC): Did you rely on test load deflections?
"IOTTI: Yes, that's why we used finite element analysis.
If the NRC does not accept finite element analysis, then we will have to reanalyze 12 supports.
"(4) Have to give to Staff about steel. Yes, we used SA36, we have to reanalyze this. (See past transcript, re:
garbage steel.)
"(5) Moment release. Some tube steels have Mz unreleased.
Answer is that none of those; Hz is always released. This af fects their Af fidavit, where we got the Kx moment mixed up with the Mz moment. This affects their Af fidavit, where we got the Mx moment mixed up with the Mz moment. The people working on the Affidavit, they misunderstood. So we have to redo the Affidavit.
"(6) Provide prying action; have results on it but is unreviewed, but haven't shown to NRC yet. Talking about tube sizes and prying f actors and prying forces. See transcript of previous meeting.
"IOTTI: Back to No. 1: On the info on 8 patterr.s; I have not done anything'on it yet.
" FAIR: If we confirm the information (1) ti.at it was never modelled as fixed, then your Af fidavit makes unwarranted assumptions; your arelyst confused Mr with 112 and it's longer than '
20", in reality it's 48". Was this study done la a generic fashion?
"lDTTI: He did it generically on a supposed worst case.
"lPPOLVfD (NRC): When are these all due to the NRC?
'i10'0T { t Everything's due by August 29."
I2 l y _ - - - - 4 _ _ __
- 8. Applicants state:
"The major factor affecting concrete cone pullout is the strength of the concrete in which the inserts are placed. Significantly, the manufacturer's tests were ccaducted with concrete which had a strength of between 2850 and 3220 psi (approximately 3000 psi). While the ;
concrete at CPSES is designed for 4000 psi, it actually ranges from 4500 to above 5000 psi. 3. at 7." With regard to the first sentence, I agree. With regard to Applicants' second and third s'entences, the statements thesnelves and their implications are extremely misleading (to say the least), as is demonstrated from the following. Applicants state that "While the concrete at CFSES is designed for i 4000 psi, it actually ranges from 4500 to above 5000 psi." Howeve r , Applicants have forgotten to inform the Board about a few things. One to that during the time concrete pouring was taking place at Comanche Peak, Applicants had many field tested cylinders which failed to meet specifications, -epp4f:; :: ci;; :::.: th:: ""hil: th: :::::::: : OPCES i; d :ign:t f;r 5000 p:1, it : ;;117 :: ;;; f :: '500 : ch : 5000 pei." 'S :.:r, Applicants also forgot to tell the Board that it was not until ef ter concrete rebound hammer retests were performed t ut the strength of clia concrete could be stated to range from 4500 to above 5000 psi in come cases, and that in other cases, the strength as indicated by the retests were NOT chown to be an much as 4500 psi as claimed by Applicants. Further, in some cases, there is no indication that some of the concrete pours were even tested by the Swiss hammer test, much less what the concrete strength was. This can all be verified by documents which are either attached or which are CASE
)
13 __ _j
Exhibits which have already been accepted into the record. A brief summary of pertinent parts cf these documents is included as CASE Attachment D hersto, which wss prepared at my request by CASE President Juanita Ellis; I have reviewed both the sumcary and the documents and the summary appears to be an accurate representation of those portions of the documents which I want to bring to the Board's attention. In regards to Applicants' position that the concrete exieting in i the field is similar to that tested for the Richmond inserts,1 bave a few comments. A review of NCR's referenced in CASE Attachment D hereto indicates that the Applicants' concrete is not in compliance with the criginal design, and the tasting procedures used te certify this ( concrete is not in conformance with established codee fj/. Based upon a review of documents attached and already In the i record. It is appatent that the quality and coestessive strength of the concrete at Comanche Peak is it.determinata at best, and in s,ome instances appears to be deficient. This review calls into question the quality of all of App 11. cants' concrets, as discussed b? low. f2/ Note'by CASE: Itshouldbenotedthat($fr.Walsh)dsvel1analifiedto { speak to thin issue. As indicated on his resume, his areas et knowledge iceludes havicg performed testing and evaluastien of Q-listed expansion anchora in grouted bicek va114 for IE Bulletin 79-02; hr.ving analyzed and designed tatention structures, tunnels, pile f ounda:lon, anr'i a sever systea; pipe support analycle and desLgn; pipe stress analysis; escrix methods of structural analysis; structural steel design; foundation antlyris and design) structural dynamics; pile design; psestressed concrete design; and cor.cepts of ttr.neling. See CASE Exhibit 841, Pevisien to Resure o'f(Sgek WaletCj accepted into evidence at Tr. 7273; see also Board's 11/28/83 He'mcrandum and order (Guality Assuranec .for Design), p.sgae 14-16. 14 Y __ __ _ _ _ _ _ _ _ _ _ _
[ As stated in the preceding, CASE Attachment D hereto is a brief Summary of Selected Documents Regarding Concrete Pours at Comanche Peak. All of the information contained in CASE Attachment D can be verified by reviewing the attached documents or the referenced documents already in the record. One particular case in point has to do with below-design-strength concrete for pour #201-5781-001 for the Reactor #2 cavity wall. To briefly summarize the information contained in the documents: On 2/16/76, field cure cylinders for concrete pour #201-5781-001 for the Reactor #2 cavity wall of 2/13/76 were found not be in a curing box; they should have been on the pour and being cured in the same manner. (Also,'ield f cure cylinders for SWI base mat pour #035-2755-001 were not on the mat and being cured in the same manner; they were on the side of a road near the mat and were found misplaced 2/16/76.) This DDR (the DDR was the predecessor to the NCR at Comanche Peak), No. C-219R1, was closed out "Use As Is," and the corrective action was indicated to include use of the curing reports rather than the field cure cylinder strengths to judge the adequacy of curing; and it is stated " Attached also are copies of impact hammer tests performed on each of the affected i concrete placements." However, there were notcopies attached of impact hammer tests (and no indication that any were ever done) for concrete pour #201-5781-001 for the Reactor #2 cavity wall, and it appears that concrete pour #201-5781-001 for the Reactor > #2 Cavity Wall was never retested (although an impact hammer retest was done on the SWI base mat pour #035-2755-001). 15
--y g --
On 3/23/76, this same concrete pour for the Containment #2 cavity wall (#201-5781-001) was again the subject of a DDR. The disposition was that this DDR, No. C-246, was " cancelled since the ~
' field cured cylinders . . . were not, in fact, representative of the cure of the concrete placed"; and this DDR refers back to the previously closed DDR (which was closed out without the concrete pour for the Reactor #2 cavity wall ever having been retested).
It thus appears that concrete pour 201-5781-001 for the Containment #2 cavity wall was still never retested and that it was used-as-is, with the field tested cylinder indicating a strength of 3559 psi-lbs. (which is under Applicants' stated design strength) and the two standard (or laboratory-tested) cylinders ' indicating a strength of 4257 and 4219 psi-lbs. (which is under Applicants' claimed actual strength of 4500 psi to 5000 psi). The results of the brief summary of documents is very enlightening, and I urge the Board to read it in its entirety. Specifically, the Board should note: On many of the DDR's (or NCR's), there are numerous concrete pours which had field cured cylinder compressive strengths less than the 4000 psi which the Applicants claim is their design strength. However, although at one point Brown & Root informed Texas Utilities that they would retest each concrete pour which was listed on the deficiency report, the attached documents indicate that they did not. In fact, on DDR No. C-449, fer example, they only retested 6 pours out of 20; there is no indication that they 16
~
9 ,
ever retested the others; on DDR No. C-457, they retested 2 out of 16; on DDR No. C-499, they retested 17 (plus one additional second retest of one pour) out of 39; on DDR No. C-529, they retested 14 (plus additional second retests of three pours) out of 22 (a larger percentage than they tested on any of the other pours involved in documents which are discussed); and on NCR C642, they retested 8 out of 20. On CASE Attachment D hereto, there is a listing for several DDR's (or NCR's) which shows not only those field-cured cylinders which tested below 4000 psi-lbs., but also (marked by **) those standard (or laboratory-tested) cylinders which tested below 4000 psi-lbs. It is important to note that irt no instance were concrete rebound hammer tests done for the concrete where both the field-tested and the standard (or laboratory tested) concrete showed to be below 4000 psi-lbs. All of the concrete rebound hammer retests were done for concrete pours where the standard (or laboratory tested) concrete initially showed to be 4000 psi-lbs. or above. In addition, it is obvious (from the same centinuing problems with numerous concrete pours for which the field-tested, and in many instances also the standard or laboratory-tested, concrete cylinders tested at less than the design strength of 4000 psi-lbs.) that Applicants did not promptly and effectively institute action to correct the cause of the problem. Further, despite the number and extent of the problems identified on the DDR's, all of them were marked:
" Reportable Deficiency: No." On NCR C642, Revision 0 was not 17
available for file (which indicates a breakdown in document control); C642R1 was issued to delete the requirement for a Corrective Action Report (CAR) to be written up; C642R2 was issued to add back the requirement for a CAR. That CAR, S-8, is also in evidence in these proceedings, and as is obvious from a review of it, was totally inadequate and did not identify the root cause or correct the real problem. There are many other matters which I could (and probably should) address if I had more time, such as: (1) Applicants appear to be assuming that a sister pour near one which was deficient is a good pour (based on the initial field and laboratory tests similar to those which indicated that the other pour was deficient) and they use it as a comparison for the deficient pour. Applicants chose to believe the initial test results for the good pour and to disbelieve the initial test results for the deficient pour. How can they (or the Board) be certain that the tests for the supposedly good pour are correct and those for the deficient pour are incorrect? How do they know that it is not the other way around; i.e., that the tests for the deficient pour are correct and the tests for the good pour are incorrect? If this were in fact the case, it could mean that instead of the retests showing that both pours are good, it actually means that both pours are deficient. 18
, , . . - - . - , - - - , - - - , . - , ~
1 (2) Tnere is enough variation of results within the same group of comparison tests to call into question the accuracy of the tests. (3) There are documents in the record /4,/ which indicate that there were also extensive problems with the water meters which were used to measure the amount of water which went into the concrete pours; this could have an adverse impact on the quality of the concrete. Applicants have stated (Affidavit at pages 16 and 17, and alleged Material Fact 14):
" Applicants have conducted a review of a representative sample of test reports of concrete used at CPSES to assure that such concrete is essentially the same as that used in the tests. In addition, Applicants have reviewed NCRs regarding concrete at CPSES to provide additional assurance that the concrete used in these tests was representative of that used at CPSES. From our review, we conclude that test conditions are representative of conditions at CPSES."
I don't know what test reports and NCR's Applicants reviewed, but the ones which I reviewed certainly did not lead me to the same conclusion as reached by Applicants. It should be noted that Applicants did not include any documentation to support their s ta tements . As stated previously, the testing procedures used to certify the concrete at Comanche Peak were not in conformance with established codes. This is especially important since these were retests done of f4/ See CASE Exhibit 561, NCR G589, and CASE Exhibit 624, Corrective Action _ Request (CAR) S-6, both admitted into evidence in accordance with the Board's 12/7/82 Order (Proposed Findings of Fact; CASE Exhibits) and accepted into evidence during the May 1983 hearings. 19 ~ * . - , .-, .- -.- ,-_ --e- -- -- r- , ,-_,,y-, - - = . - - - - - - - - - _ _ _ _ _ _ _ _
concrete pours where field-tested concrete cylinders tested out at less than desired (in CASE Attachment D hereto, only those which tested at less than the alleged design strength of 4000 psi-lbs. compressive strength are discussed). As indicated in the documents referenced in CASE Attachment D, the 2 retests which were done apparently used a concrete rebound hammer test to verify that concrete which appeared to be defective or weaker than desired was, in fact, adequate. This test is a rebound test and would fall under ASTM designation C805-79 (see Attachment E hereto). This ASTM specification states at paragraph 3.2:
"This method is not intended as an, alternative for strength determination of concrete." (Emphasis added.)
This is the only applicable specification for a rebound test which I have been able to find in the limited amount of time I have had. As stated in paragraph 3.1 of ASTM C805-79:
"The rebound number determined by this method may be used to assess the uniformity of concrete in situ, to delineate zones or regions (areas) of poor quality or deteriorated concrete in structures, and to indicate changes with time in characteristics of concrete such as those caused by the hydration of cement so that it provides useful information in determining when forms and shoring may be removed."
It appears 'that Applicants have used a concrete rebound test to qualify substandard concrete to justify poor concrete in the field /5/. l Even if one were to accept the concrete rebound test as an acceptable method for retesting the strength of the concrete (which f5/ It should be noted that (although the Swiss hammer test is referenced , in some of Applicants' letters included in documents referenced in CASE , Attachment D hereto) the specific type of concrete hammer test used is not indicated on the test reports themselves. 20
,.m_, -. , , - - - . , - - - , - - - - , . _ , , , , , - , - - - - - , _ - - - - - - - - - - - - , , . , , - - - - - - - - - - ,--,,.----,,,-sw... - - - - - - - , - - , , - , , , _ 4 . - - - - , - ,-,-m-
would be contrary to ASTM C805-79), ASTM also sets forth certain specific criteria for testing and reporting, several of which Applicants have not met. (I do not have time to go into detail F regarding these, but some information in this regard is contained in the attached documents f6/.) There are also some additional cautions and drawbacks regarding theuseofconcretereboundtfswhicharediscussedinAttachmentsE, F, and G hereto. For example: The tests must not be regarded as a substitute for standard l compression tests. The method should be used for comparative purposes. The method tests only the surf ace and does not give a good indication of the actual strength of the concrete. The results of the tests are affected by a wide variety of conditions, such as the age of the test specimen, the surf ace and inkenalmoistureconditionoftheconcrete,thetypeofcoarse A aggregate, the type of cement, the type of mold, the cabonation of f6/ See: Attachment E, American Society for Testing and Materials (ASTM) C805-79; Attachment F, pages 27-30 through 27-33, Handbook of Structural Concrete, Edited by: F. K. Kong, Professor of Structural Engineering, University of Newcastle upon Tyne; R. H. Evans, CBE, Emeritus Professor of Civil Engineering, University of Leeds; Edward Cohen, Managing Partner, Ammann and Whitney, New York; and Frederic Roll, Professor of Civil Engineering, University of Pennsylvania; Attachment G, pages iv through ix, xiii through xv, 3 through 51, and 166 through 169, TESTING HARDENED CONCRETE: NONDESTRUCTIVE METHODS, V. M. Malhotra, Head, Construction Materials Section, Canada Centre for Mineral and Energy Technology, Department of Energy, Mines and Resources, Ottawa, Canada; published jointly by the Iowa State University Press and the American Concrete Institute (ACI). 21
- --..-- --, -, ----y--- .
the concrete surface, the smoothness of the surface under test, the size, shape, and rigidity of test specimens, whether or not the same test hammer is used for the tests, hammer type, etc.
'Much of this information is not indicated on the concrete rebound hammer test reports referenced in CASE Attachment D hereto.
Once Applicants discovered that there was the possibility of deficient or defective concrete, what they should have done to test it was to drill a core sample for each pour and test that. My brief review of the documents referenced in CASE Attachment D hereto, coupled with the statements made in ASTM C805-79 and other documents which I have attached, have raised doubts in my mind, not only regarding the Richmond inserts, but also regarding the quality of all of the concrete at Comanche Peak.
- 9. Applicants state:
"From conservative calculations, the additional strength of the
- concrete of CPSES results in a much higher ultimate failure load of the insert than established by the manufacturer's tests. Accordingly, use of allowable loads higher than recommended by the manufacturer was justified based on the higher ultimate loads for the particular circumstances at CPSES, and the safety factor specified by the manufacturer would be essentially met. Id. at 7-11."
I disagree with the whole premise of first sentence. See answer 8 above regarding Applicants' erroneous statements about the actual strength of concrete at CPSES, which in turn means that Applicants' whole premise and justification has an erroneous basis. Therefore, 22
l l Applicants' admittedly "much higher ultimate failure load of the insert than established by the manufacturer's tests" is unacceptable, and, contrary to Applicants' assertions, the safety factor specified by the manufacturer would not be essentially met. In addition, the Applicants are neglecting a very important factor when they use the equation shown on page 8 of their Affidavit. The equation shown is based on the strength design method (see Attachment H hereto, CASE Exhibit 778, ACI 349-80, " Code Requirements for Nuclear Safety Related Concrete Structures (ACI 349-80) and Commentary -- ACI 349R-80," page 349-77, B.4.1.; see also page 9 of NRC SIT Report, Staff Exhibit 207). If Applicants' position is based on this design method, the Applicants do not apply it correctly. For the strength design method (also known as the ultimate strength design method), two factors come into play: They are the undercapacity factor and the load factor. The undercapeity factor takes into account the mode of failure. On page 8 of Applicants' Affidavit, they refer to the following equation: T=4/('fc)b This equation is the shear strength of the concrete per square in., for concrete pullout, as also referenced in CASE Attachment H hereto. The phifactor(f)isequalto.85forreinforcedconcreteand.65for unreinforced concrete (see CASE Attachment I hereto, Applicants' 7/11/84 letter to Staff Counsel Geary Mizuno, which was sent without enclosures to the service list except for the Staff and CASE, 6th page of Attachment I). 23
As stated in B.4.1 of ACI 349, page 77 (CASE Attachment H hereto), the use of these design provisions is based on the strength design method. The strength design method requires all loads to be increased by s' load factor, which the Applicants have not done. What the Applicants must jijl to utilize this equation is to increase all their loads by aload factor. For example, a load factor for dead load is 1.4. A load factor for seismic is 1.9 (see Applicants' FSAR, Applicants' Exhibit 3, Section 3.8.4.3.2, equation 1). The Applicants have not in the past or in their present Motion mentioned the additional requirement of a load factor when using this equation. What the Applicants are relying on is the use of one equation for undercapacity (the phi factor) without recognizing a requirement for the load factor. The load factor and the phi factor are not used when i using the working stress design method and applying a factor of safety of 3, which would cover an undercapacity factor (which is phi) and the overload factor. This is another case of apples and oranges, but in this instance Applicants are trying to mix them and tell the Board they've got a better product now. Consequently, their statement that the allowable loads which the Applicants use, which are admittedly higher than the manufacturer's allowables, has a large error because the Applicants forgot to increase the load, which is required when using their selected formula.
~
Therefore, Applicants' conclusion in the second sentence is based on erroneous information. This is further demonstrated in Applicants' Affidavit (bottom of page 10, continued on top of page 11) regarding 24
= "
the basis for the shear allowable value. In Applicants' answer, they discuss the ultimate shear capacity of a 1" insert's being equal to the tensile capacity and that the anchor stud bolt's shear capacity governed over the insert's capacity. This would indicate that the bolt governs and not the insert, and that the allowable should be based on the bolt and not the capacity of the insert (as the Applicants have stated in the first three sentences of their answer at the bottom of page 10). The last sentence in answer to that question (at the top of page 11) states that the manufacturer's working shear load is 18 kips. This 18 kips corresponds approximately to the allowable shear load of the A307 bolt (17.67 kips). The Applicants' method of combining an ultimate load and then using a ratio of a working load indicates the Applicants' practice of combining apples and oranges and arriving at a supposedly better product. It is also noteworthy that the Applicants neglected to provide any calculations or documentation to show that they actually did this in the original design. ,
- 10. Applicants state:
1
- "The low strength threaded rods / bolts, used in the vast majority of all Richmond inserts of concern, have lower allowable loads than the allowable loads for the Richmond inserts used in the CPSES design.
Accordingly, for the allowable loads for pure tension or shear, the governing limits on design would not be the allowables for the inserts, but rather (in most cases) the allowable loads of the threaded rods. Id,.'at 10." I agree with Applicants' first sentence that the low strength threaded rods / bolts are used in the vast majority of all Richmond inserts of concern. As we have shown in answer 7 above, the allowable loads which the Applicants use for the threaded rods are also in error. 25
---------.r e, . -
-n n ..,y ., n. . - - - - - . . - - - - , - .
,,n. ,,-- -,
But for those supports which do use a high strength bolt in which the insert governs, the Applicants' allowable values conflict with the manufacturer's allowables and are based on the misuse of the strength design method, as shown in answer 9 preceding.
- 11. Applicants state:
" Shear tests were conducted at CPSES on 1-1/2 inch Richmond inserts in March 1983. The results of the tests indicated that the performance capabilities in shear of the Richmond inserts used at CPSES exceed the design allowables by a ratio in excess of 3.3 to 1. Because the tests did not go to failure, the actual ratio is higher and the results are conservative. Jd. at 11-12."
The shear tests to which Applicants refer in the first sentence are contained in CASE Exhibit 834 (Attachment C hereto). The factor of safety which the Applicants reference is utilizing the lower allowable of the threaded rod, not the actual Richmond insert capacity. When utilizing the Richmond insert capacity, the factor of safety is equa) to 58.3 divided by 25 - 2.33. This is considerably less than v'.at the Applicants are trying to convey to the Board. The test performed in 1983 did not represent the actual concrete used in the field (see answer 8 preceding). As the Applicants freely admit (Affidavit at 11), the concrete strength utilized in the test block was 4600 psi -- however, this was based on field cured concrete. The lab cured concrete utilized in the test was 5610 and 5570, and averaged 5590 (see first page of Appendix 1 of Attachment A (the 1983 Test Report) to Applicants' Affidavit). Thus, as desenstrated in answer 8 preceding, Applicants are making an illogical and unacceptable 26
, , , , . - - n---. .-,-c'. - . . - - - . , - . .
comparison between field-tested concrete (used in their tests) and the concrete rebound hammer tested concrete (at Comanche Peak) -- apples and oranges again. If the Applicants wished to use and refer to the compressive strength of field-cured samples in their test report as being conservative, then all those NCR's could not have been dispositioned "Use As Is" and accepted based on the concrete rebound hammer test. One cannot compare the field-cured concrete used in the tests (which was acceptable for their test report) with the field-cured concrete which exists at Comanche Peak (which was unacceptable). It must be remembered that the field-cured test results for Comanche Peak (as discussed in answer 8 preceding) for which the NCR's were written, reflect the actual field conditions, as do the field-cured specimens which the Applicants prefer to reference in their test report and in the Affidavit. But this is a comparison which Applicants obviously do i not want to make, for obvious good reasons. Since Applicants wish to discuss apples and oranges, I shall too, but I will separate them, rather than combining them as the Applicants have. I shall first discuss what the results would be if one only considered lab-cured samples. In the second case, I shall discuss only field-cured samples. Applicants have used lab-cured samples with a compressive strength equal.co 5600 psi in their tests; however, the allowable values (based on a design strength of 4000 psi concrete) must be reduced to a 4000 psi concrete value. To reduce it to 4000 psi concrete, all one needs i to do is to take the square root of 4000 divided by 5600 = .845. (This 27
1 I is the same method which the Applicants used to increase the tension allowable for the 1-1/2" diameter insert to 25 kips from 21.7 kips (as disussed at the top of page 11 of Applicants' Affidavit), although not
?
explicitly stated that way.) Since the majority of the connections with the inserts is made with an A36 rod, the allowable for the insert should be based on the capacity of the insert utilizing the A36 rod. The Applicants, when testing the A36 rod with the Richmond insert, arrived at an average ultimate strength of 61.8 kips (see Attachment A, page 4, attached to Applicants' Affijavit). Since we are concerned with 4000 psi concrete, the 61.8 kips must be decreased to 61.8 times
.845 = 52.2 kips ultimate capacity. Since the manufacturer requires a factor of safety of 3 and the Applicants claim they have a factor of safety greater than 3, all we need to do is take the tested strength
.1 value of 52.2 kips (for the proper design load) and divide it by 3, and we arrive at 17.4 kips, which is far less than the 25 kips which the Applicants are utilizing for the insert, as shown in the PSE manual (see CASE Exhibit 724, page 1 of 2, Section VI, accepted into the record at Tr. 6471). This is based solely on the capacity of the insert utilizing an A36 threaded rod, which is commonly used at Comanche Peak. (This should not be confused with the 17.67 kips which is the allowable capacity for an A307 bolt.) The other case would be comparing field-cured samples. The field-cured samples utilized in Applicants' test have an average compressive strength of 4600 psi. The allowable Richmond insert value utilizing i the SA-36 threaded rod would have an ultimate strength equal to the 28
~
square root of 4000 divided by 4600 times 61.8 - 57.6 kips. For a factor of safety of 3, the allowable working value should be 19.2 kips, still far less than the 25 kips which the Applicants utilized. But more importantly, is that if one were to accept Applicants' position (as stated in the Affidavit) that the average strength for the test was 4600 psi for field-cured samples, then the Applicants cannot use the concrete that failed to meet the field-cured test results which are listed in the NCR's discussed in answer 8 preceding. As demonstrated in the preceding, Applicants' statements that "the performance capabilities in shear of the Richmond inserts used at CPSES exceed the design allowables by a ratio in excess of 3.3 to 1" and "the actual ratio is higher and the results are conservative" are incorrect and unsubstantiated. In summary, the Applicants' test results, when properly and consistently applied, utilizing the SA-36 threaded rod, arrive at allowable loads less than the values utilized by the Applicants, but are approximately equal to the values recommended by the manufacturer. In addition, the manufacturer did not state in its test results what the strength of the threaded rod was for his test, the Applicants have no basis for assuming that it was based on a high-strength thecaded rod. The Applicants had no basis for combining the ultimate strength design criteria with the working stress criteria (as shown in answer 9 above), or for assuming the concrete strength in the field (i.e., concrete actu..11y utilized at CPSES) is of equal strength to that which was tested in Applicants' Test Report. Based on only these three items, it can be concluded that the Applicants had no basis i 29
for having an allowable strength of the insert greater than the manufacturer's allowable, and in doing so, the Applicants have combined the working stress method with the ultimate strength design method, have' utilized field-cured samples with lab-cured samples, and always taken the most optimistic approach, which has resulted in an unconservative and overrated capacity of the insert. One additional topic which needs to be discussed is in regards to the generic deflection criteria which the Applicants use and these test J results. (See discussion at page 4 of CASE's Answer to Applicants' Motion for Summary Disposition Regarding Use of Generic Stiffnesses Instead of Actual Stiffnesses in Piping Analysis.) The Applicants utilize a generic deflection criteria in the design of their pipe i supports. When calculating the deflection due to applied loads, the support points are assumed to be fixed; i.e., they do not translate (nove in a plars). The Applicants also claim and have shown that they are currently using 17.7 kips for the SA-36 threaded rod in their calculations. Referring to the load deflection curves provided in Attachment A, Appendix 3, third page from the last, the bottom three curves are for the SA-36 rod. On the left-hand margin is the applied load (Total Load - Kips) and at the bottom is the deflection due to the applied load (Deflection - Inches). At the design load for the threaded rod (i.e., 17.7 kips), test No. 9, the bolt had deflected .138 inches. In test No. 8, the bolt had deflected .363 inches. And in test No. 7, the bolt had deflected .425 inches. The generie deflection criteria limits the movement of the support to .0625 inches. The 30
deflection results from the Applicants' attachment clearly demonstrate that the Applicants are not exercising proper engineering when they , utilize the bearing type connection which allows deflections to reach this> magnitude (i.e., between 2 times and almost 7 times as such as allowed by the deflection criteria, or an average of .4 inches for the 1 design load). It should be noted that the preceding is based on the results achieved in Applicants' tests. However, as discussed by Applicants' Witness Dr. Iotti and Mr. Fleck of the NRC during the 8/8/84 meeting between Applicants and NRC Staff /7,/ (and as demonstrated in Applicants' test), the material from which the A36 rod is made has a lot of variability, and there is no assurance that the actual deflections experienced would not be even greater than was shown in these tests.
- 12. Applicants state
" Test results for the specimens with and without the 1 inch washer were comparable, indicating that the presence of the washer has little effect on the performance of the threaded connection / bolt or the Richmond insert. If any bending stress is introduced in the bolt as a result of the 1 inch thick washer, toe tests (sic) results show that it is not significant. Jd,. at 12."
Applicants have not proved their statements. Applicants state that a 1" washer was used in the test. However, in the Test Report itself (Attachment A to Applicants' Affidavit), it is stated (page 2): f7/ See answer 7, pages 10 and 11, herein. 31 i
". . . a 1-inch thick plate was inserted between the shear plate and the insert, representing the ' washer' used frequently at this location in pipe hanger installation."
There is no indication of how Applicants determined that the 1" thict plate accurately represented the washer which, according to Applicants' Affidavit, is frequently used. It may be that it is representative, but there is nothing in the Test Report or Applicants' Affidavit to assure that this is true; therefore, Applicants' conclusion is inaccurate. Also, the Applicants are only relying on the test for high strength bolting material in regards to tests with and without washers, and not the SA-36 rods (which are used in the vast majority of all Richmond inserts of concern, as stated by Applicants in alleged Material Fact 10); the SA-36 rods were tested only with washers. In addition, the SA-36 rods were secured to the plate with double nuts (Test Report, pege 3). This is not representative of the Richmond insert / tube steel /SA-36 connection used at Comancho Peak. For this reason, the Applicants' statement in regards to bolt bending is unsubstantiated. A very important statement is contained in the Affidavit which is not included in the alleged Material Facts. At the bottom of page 12, it is stated and underlined:
"These results justify the shear allowables regarding Richmond inserts used by Applicants in the design of CPSES." (Emphasis in the original.)
As shown above in this answer and in answer 11 preceding, the Applicants' test results cannot be used to justify the shear allowables which they are presently using. 32 O
- 13. Applicants state:
" Applicants performed another series of tests in March and April,1984.
These tests were performed to determine the load carrying characteristics of 1-1/2 and 1 inch Richmond inserts (the inserts of concern) when subject to tension only, shear only and combined shear . and tension loadings. The test results confirm the judgment of Applicants that (1) shear and tensile ultimate capacities are nearly the same and (2) the actual factors of safety are in excess of 3.0 for shear, tension and combined shear-tension loadings. Id. at 13-16." I do not agree with Applicants' conclusions. The Applicants recognize the difference between the ultimate load and the failure load (page 1 of Test Report, Attachment B to Applicants' Affidavit). It is the failure load which is of concern. As discussed in answer 8 preceding, the concrete used in Applicants' tests is not representative of that which is used at Comanche Peak. The concrete used for the tests had a compressive strength of 5,450 psi (Appendix 2, Attachment B te Applicants' Affidavit). The concrete design strength at Comanche Peak is 4000 psi and field tests have shown the concrete strength is less than 4000 psi. But assuming a 4000 lb. design strength, the factor of safety presented 9 by Applicants should be reduced by a factor of the square root of 4000 divided by 5450 = .86. Therefore, the test results are not reflective of the design of Comanche Peak. Also, these tests were conducted using rebar. As discussed in more detail in answer 15 following and in CASE's Proposed Findings (VII
- 16 through -23 and XXVII - 42 through -48, especially pages VII - 21 and -22, and XXVII - 42 through -48), there are places at Comanche Peak where such rebar does not exist. As the Applicants have shown the NRC 33
Staff, the difference between the phi factor with rebar and without reber is .85 to .65, respectively (see answer 9 preceding). Since there are areas where rebar could be missing or rebar will not be within the shear cone of the Richmond insert, the factor of safety which Applicants arrived at should also be reduced by the ratio .65 divided by .85 = .76. Therefore, the test results are not representative in all cases to Comanche Peak in this regard. (See also answer 15 following.) Utilizing just the two items discussed in the previous two paragraphs, the average factor of safety for the 1-1/2" Richmond insert in shear reduces from the 3.49 listed on page 5 of Attachment B to Applicants' Affidavit to 2.28. On page 6 (of Attachment B to Applicants' Affidavit), the average factor of safety for tension reduces to 2.13 from 3.26. For the combined shear and tension test (page 7, Attachment B to Applicants' Af fidavit), the average f actor of safety would be reduced to 2.4 from 3.68. It should be noted that in all of these cases, this is the average factor of safety, not the minimum factor of safety. Also, these tests do not reflect the Richmond insert /SA-36 rod combination. Only high-strength A-490 bolts or SA-193 Crade B7 threaded rods were used in the tests. (See page 14 of Applicants' Affidavit, and page 4, item 3.0 TEST PROCEDURE, Attachment B to Applicants' Affidavit.) Further, contrary to Applicants' statements at the bottom of page 14 of their Af fidavit, Applicants have used the wrong allowables for inserts which have been used at Comanche Peak, as discussed previously. 34
- - -- __ _ ,, -.--- ,- , __--m .,
The Appliennes also neglected to test for the yield point; 1.e., the load at which the insert and threaded rod no longer resume their original position. By using the allowable values for tension and shear and increasing those values by 1.5 (factor of safety for elastic ; analysis), then testing the connection to that load, when the load is removed the threaded rod and insert should be in their original position. This should be done several times, so that cyclic capabilities can also be determined. The Applicants, in addition, did not consider the material properties in the event of a LOCA and how the insert would behave. For additional information, see CASE's Proposed Findings at page VIII - 15 through VIII - 17. For the reasons stated in the preceding, Applicants' test results are not representative of the actual conditions needed at Comanche Peak, and the test results cannot be used to draw the conclusions which Applicants have attempted to reach. By reviewing the test results performed by the Applicants, and the procedures that they utilized, some conclusions about friction-type connections can be drawn. In test A, it is observed that there was no movement of the bolt in the tension test for the first applied load. The applicants' procedure was just to tighten the bolt snug tight. As can be demonstrated, the snug tight for the tension test was sufficient to prevent movement, but not sufficient to avoid movement in the shear test. I l ' 35
- 14. Applicants state:
"The concrete used in the tests was representative of concrete in the plant. Applicants have conducted a review of a representative sample of test reports of concrete used at CPSES to assure that such concrete is essentially the same as that used in the tests. In addition, ,
Appifcants have reviewed NCRs regarding concrete at CPSES to provide additional assurance that the concrete used in these tests was representative of that used at CPSES. Id. at 16-17." See answers 8 and 11 preceding.
- 15. Applicants state:
"To be very conservative, the tests conducted in March 1984 employed two layers of reinforcement rods rather than 4 layers used in the prior test and at CPSES. The capacities of the Richmonds were not impaired even with this reduced rebar. Id. at 17."
As the Applicants stated in their 7/11/84 responses to questions posed by the NRC Staf f (CASE Attachment I hereto), on page 6 of Applicants' attachment:
"It is not intended to imply that there is little difference between no reinforcement and reinforcement, but simply that there is little dif ference between types of reinforcement, te 2 layer vs 4 layer, rebar size chosen."-
The placement of the insert with respect to the reinforcement is very critical to its capability. For an example, in a square that is 12" x 12" which is bounded by reinforcement on all four sides, if one were to place the insert at any one of the corners, the reinforcement would assist the insert in its strength capability. If one were to take the center of the square and place an insert, and the reinforcing bars were not within the shear cone of the insert, as would be the case with this example, the reinforcement does not assist in the Richmond 36
4 insert's strength capability. That is why it is important to test the Richmond insert in unreinforced concrete. During construction, Richmond inserts are attached to the form work for walls, beams, and ceilings, and the location of the Richmond insert with respect to the reinforcement is not determined. Since the Applicants have not demonstrated that all the Richmond inserts are located adjacent to reinforcement, the test should have been done in unreinforced concrete. Also, testing in unreinforced concrete is necessary to accurately represent what actually exists in some places at Comanche Peak, as discussd in answer 13 preceding. r
- 16. Applicants state "The difference in reinforcement in the concrete (a concern expressed by CASE) is not significant when compared to other factors. If rebar was (sic) a dominant factot, it would be evident from a comparison of the results of the March 1983 tests (using 4 layers of rebar) and the March 1984 tests (using 2 layers of rebar). However, a comparison of those results (including bolt deflections) indicates that the amount of rebar is not a significant factor. Jji . "
See answers 8 and 15 above. I
- 17. Applicants state:
"To study the validity of Applicants' use of its calculational methodology, Applicants performed detailed finite element analyses utilizing the STARDYNE computer program. The results of the analyses indicate that the formulas used by Applicants did not precisely model the resulting forces. The formulas used by Applicants to calculate axial torsion resulted in a calculated force that was low for all but six supports by as much as 18 percent (in six specific supports it was low by 33%). However, because of conservatism in the methodology and process used, in all cases allowables would not have been exceeded.
Id. at 21-24." j 37
.___ _ _ _ . ._ - I_ _ _ - __ _ ._ -_ __ - __ __~
Applicants admit above that, according to their own STARDYNE finite element analysis, the "forumlas used by Applicants to calculate axial torsion resulted in a calculated force that was low for all but l six supports by as much as 18 percent (in six specific supports it was low by 33%)" (emphasis in the original). When one combines this fact with the fact that Applicants were also using assumptions for the amount of rebar and the strength of concrete which were fatally flawed, Applicants' statement that "because of conservatism in the methodology and process used, in all cases allowables would not have been exceeded" is unsupported, undocumented, and without technical merit. Applicants'
" conservatism" is in fact unconservative, and misleading as shown in answer 19 following. (See Footnote 2, page 14, herein.)
The Applicants utilize an unusual design configuration, as has been stated before in the record, and none of the Applicants' witnesses or CASE's witnesses had seen this type of support configuration (see CASE's Proposed Findings, pages VII - 1 through -3). The Applicants have not shown proof why they decided to use this unique design generically throughout the plant. The Applicants have attempted to utilize a finite element analysis to demonstrate that their position was correct. The results of the finite element analysis are summarized on pages 22 and 23 of Applicants' Affidavit. The results of the analysis were provided with only a summary and a math model, but no calculations or assumptions utilized in those calculations were provided. 38
d Referring to items a) through g) in Applicants' Affidavit at pages 22 and 23: Item a) of Applicants' summary proves CASE's point. It should be remekbered that Applicants' expert witnesses argued that the center of compression would not be at the tangency point of the tube steel member , , because there would be some deformation of the tube and the centerline would not be at the tangency point (see CASE's Proposel Findings at pages VII - 31 through VII - 33). As the Applicants now admit (page 22,a),ofApplicants' Affidavit),(Mr.Doyl[)aswellastheBoard, t was correct with regards to the tangency point. It should be noted , that this is contrary to what Applicants represented to the Board (page 41, Applicants' 1/17/84 Motion for Reconsideration of Memorandum and Order (Quality Assurance for Designy, where they discussed their phantom experts: -
"We have no references to additional evidence to help clarify.
However, we have obtained the independent opinions of outside experts on this point, and each agrees with the positions taken by Applicants and Staff." ' (See also Board's 12/28/83 Memorandum and Order (Quality Assurance for Design) at pages 62-63, and Board's 2/8/84 Memorandum and Order (Reconsideration Concerning Quality Assurance for Design), at page 32.) Due to the fact that I have not seen the calculation results or assumptions used for those calculations, I cannot agree with Applicants' last statement in a). It would appear that the Applicants assumed that there were no pretensioned forces to hold the bolt down and therefore they have not considered the consequences when using a high-strength halt in this type of connection when the bolt is l pretensioned. 39 t : -
The Applicants state in item b) that the distribution la reasonably linear. A parabolic curve can also be considered reasonably linear. Referring to Attachment E-2, Figure E-2 (b), it will be noted, e i and it is underlined "NOT TO SCALE. Starting at Section (1)-(1), we , see there is a difference between 38# and 40#, which is 2#. If the , distribution were in fact linear: ( the next value should be: but it isn't, it is: 36# 37# 34# 36# 32# *
*and it ist 32#
30# 27# 28# 22# 26# 11# 24# 1# Of the nine pointa considered, only two of them were on a straight line. (Sections (5)-(5) and (9)-(9) could be similarly analyzed.) The same thing could be said for a line drawn through a circle, leading to the conclusion that circles are not circular but linear. The attached diagram illustrates what the load distribution would be to scale (see CASE Attachment J hereto). In item c), the Applicants address the non-linear (termed by Applicants to be " quasi-linear" which is obviously non-linear) force distribution in the concrete, which is contradictory to their item b)
- above. In the second paragraph, the Applicants make an attempt to ,
qualify their mistake. As shown in item b) above, there is no 40 e
- , . -. ., -e . - . - .._ _ _ _ -- ._. _ , - . _
l i l l triangular distribution of the stresses. But if one were to say there is a triangular distribution going from the centroid of the bolt to the edge of the washer, the centroid of the load may coincide with the tangency of the tube steet member; but that is immaterial and was not discussed prior to this Motion and is just be a coincidence. There is no basis for it. Therefore, Applicants' statements regarding "the neutral axis adjusting accordingly" is unsubstantiated. The Applicants claim in ites d) that there is less than a 25 per cent increase in bolt tension when considering the tangency point which CASE has argued is correct. They refer back to sote 9, However, note 9 states that there is a 33 per cent increase, which does not appear to be consistent within the Affidavit. I have not seen any calculations on which Applicants relied regarding this, but it does appear that che Applicants are addressing only four supports out of the whole plant which fall into this category. They do not mention the other supports which would have an increase. The sensitivity study referenced in item e) was not provided by Applicants with their Motion. The stiffness of the concrete is proportional to the concrete compressive strength; the concrete compressive strength is in strong dispute (see answer 8 preceding). One cannot tell exactly what Applicants mean when they state: " Applicants ran a sensitivity study and the stiffness of the concrete was varied." It is not clear if they mean that they ran a sensitivity study in which they varied the stiffness of the concrete, or if they ran a sensitivity study and found from that study that the stiffness of 41
I the concrete varied. With regard to Applicants' statements regarding the distribution of compressive stresses being " essentially" linear, see discussion regarding item b) preceding. Since I do not have Applicants' sensitivity study, I have reason to disagree with their last sentence. If the concrete lacks sufficient stiffness compared to the tube steel member, the centroid of the compressive force in the concrete would be less than the tangency point where the tube steel member contacts the washer. It appears from what Applicants have stated in item f) that when the bolt is at the maximum value permitted by the design criteria, the effect is as if one had drilled a hole through a circular pipe. When one torques the circular pipe, the only restraining effect could be due to the bolt, since there is no tangency point (because it is circular); i.e., there is no coupling action between the bolt and the washer, as Applicants have stated. This is a complete change in the design criteria and the results would indicate that the bolt must take the total torsional load by itself without any coupling. See CASE Attachment K hereto, CASE Exhibit 669B, Attachment to fhoylje ) Deposition / Testimony, item 8P. Regarding item g), see answer f) preceding. Further, Applicants' statement (middle of page 23 of Affidavit) that this will result in no adverse effect on the safety of the plant remains unproven. Nowhere in their discussion do the Applicants , discuss the deflection of this type of connection. The deflection is related to the generic stiffnese Motion for Summary Disposition. As i 42
----w,--, - , - - - - - - - , - , , , , - - --
will be shown later in answer 18, the combined effect of the Richmond insert /A307 bolt / tube steel connection exceeds Applicants' prophested factor of safety as well as exceeding the assumed deflection criteria of the supported connection by an amount equal to infinity. The ; consequences of the results due to the tests were not discussed within this portion of Applicants' Affidavit, but I shall discuss them later. On page 23 of their Affidavit, Applicants allege that "As discussed below, this will result in no adverse effect on the safety of the plant." (Emphasis in the original.) however, it should be noted, first of all, that Applicants do not state that they included all supports in Table 1. They use two caviats when they use the terms "may be,primarily loaded". This would appear to mean that they are not sure that they considered all supports and that they did not discuss those supports which were loaded previously with 49% in shear or torsion. In addition, the Applicants state that instances rhere item f) above exists are few, but they admit that 18 out of 102 supports exhibited the extreme case, which is 18%. The Applicants did not state what percentage of the supports were in between the extreme case of item f) above and the cases where the bolt was on the centerline of the tube. I asked for (on discovery) the calculations and drawings for 20 supports out of the alleged 182 supports which were the basis of Applicants' analysis regarding A500 Steel; these 20 supports wera to meet the following criteria: large bore; large loads (both in magnitude and % of allowable); with Richmond inserts where there are two or more spans; and members that are in bending. It should be 43
t noted that none of those supports were included in Applicants' Table 1. Included in those 20 supports were 5 supports which had Richmond inserts where Richmonds were called out on the drawing (some had
?
Richmonds which were attached to other supports, but I did not include those). On those 5 supports there were 23 Richmond inserts. On drawing AF-1-001-035-Y33R (CASE Attachment L hereto) ty re are 3 Richmonds shown but the location with respect to the centerline of the tube is not indicated. In regards to the remaining 20 Richmonds, 14 of the Richmonds -- or 70% -- were located of f the centerline of the tube. This calls into question Applicants' statement on page 23 of their Affidavit where they state that "the preponderant number of supports (90%) have tube steel connected to Richmond inserts at the centerline of the tube steel (zero offset) or with small eccentricities". It is not reasonable to believe that the the small random sample which I looked at in regards to a coupletely different Motion for Summary Disposition would have 70% of the known Richmond inserts located off
- the centerline of the tube if Applicants' statement were true. Not l
only are the Richmonds shown to be off the centerline of the tube, on l drawing CC-1-028-024-S33R, the Richmond is at an angle (as shown in l Sections E-E and B-B) which was not considered by the Applicants in their Motion. Also, on this same drawing, one will note that there is no washer between the tube steel member and the face of the concrete. l This condition was not considered by the Applicants in their Motion. On page 24 of Applicants' Affidavit, they state that ". . . the maximum possible underestimation of the tension resulting in the bolt 44 .
l l is about 25 percent." But in Table 1, Part A, attached to Applicants' Affidavit, is a list showing bolt interactions. A bolt interaction less than or equal to 1 is commonly considered acceptable. If the Applicarts had underestimated by 25% or 33%, the new bolt interaction should not exceed 1.33. But reviewing Table 1, many of the bolt interactions exceed 1.33. In addition, the Applicants will only be addressing in the future those bolt interactions which are designated with an FE (see footnot'e at bottom of Table 1). The 25% increase which the Applicants are discussing at such length in their Morion is just a small part of the problem, as will be discussed following.
- 18. Applicants state:
"In the proc 4ss of performing the finite element analyses, regarding axial torsion, Applicants noted that when it was assumed that no
- clearance existed between the tube steel and the bolt, a shear couple is created which places the bolt in bending. The effect becomes
, pronounced when the bolt holes are offset to their largest values. To investigate the possible adverse effects on the connections, Applicants developed a screening criterion based on very conservative assucptions.
The factors of safety inherent in the methods of calculation employed to establish the criterion are in excess of 10. Id. at 24-5." i I disagree with Applicants' statements. The screening criterion which Applicants claim is based on very conservative assumptions is not conservative. The factors of safety in excess of 10 which Applicants i claim are " inherent in the methods of calculation employed to establish the criterion" are in f act incorrect and undocumented, as discussed below. On pages 24-25 of Applicants' Affidavit, they discuss the
" screening criterion" by which they judged which particular supports l
f 45
.4- -@
require closer scrutiny; they claim this this screening criterion was
" based on a very conservative analysis." I disagree with this representation. The Applicants are attempting to justify a criterion which allows bolt bending to exceed the interaction ratio of 1 and go as high as 1.75. The two bases for their decision are as follows:
(1) The Applicants c' aim the FE method predicted the stress to be 33% lower than using standard manual calculations. Although what they stated in this regard is true, it is based on an inadequate , number of elements 18/. In Attachment E-3 to their Affidavit, the Applicants state that the average stress for node point 311 is based on averaging the results of elements 287, 297, 307, and 317. Figure E-3(1) contains a portion of the math model for this analysis. The averaging of these four particular elements to determine the stress at node 311 is improper. Going for the center of the bolt node 281 to node 311, there is only one node point in between; i.e., node 291. The Applicants' method of modelling a small number of large elements resulted in the lower stresses. To demonstrate that the position the Applicants took was in error, consider the following: Figure 1 (see CASE Attachment M hereto) is of a plate 1 inch wide and 4 inches long. To determine the moment of inertia, one can use the 1/12 bh 3 standard equation 4or can use a more basic approach which is to use the definition of the moment of inertia, and that is the summation of each element's area times the distance from the center of gravity of each area to the axis under consideration, commonly the neutral axis (NA). For Figure 1, the
]8/ As shown in my resume, I do have knowledge in the finite element method of analysis. (See footnote 2, page 14, of this pleading.)
46
l moment of inertia is equal to 5 in.4 . If one were to use just two areas instead of four, the moment of inertia would be (2)(1) + (2)(1) = 4 in.4 As the number of areas gets larger and each element's area gets smaller, the value for the moment of inertia approaches 5.33 in.4 The tse of integral calculations transforms this summation of areas times distances squared for a rectangle to 1/12 bh 3. The same process can be demonstrated for a circle, which is under consideration. To determine the section modulus, the moment of inertia is divided by the distance to the outermost centroid. For Figure 1, the distance to the outermost centroid is 1.5 inches. The resulting section modulus is 5/1.5 - 3.33 in.3 For just two elements, the section modulus is 4/1 = 4 in.3 For the standard equation, based on integral calculus, the section modulus is 5.33/2 = 2.67. The difference between the two values (i.e., with four elements versus the value based 'on integral calculus) is 3.33/2.67 = 1.25; and for two elements, the ratio is 4/2.667 - 1.5. In other words, when more elements are used, the results will approach the value obtained by integral calculus (or, as the Applicants refer to it, " simple flexural behavior"). For the Applicants to obtain more realistic results, the finite element analysis would require more elements that are smaller. Although the stresses which the finite element analysis shows will l always be on the low side, the values will approach a more precise i value. (2) The Applicants also state that the interaction ratio can be l l as high as 1.75 due to the allowable bending stress. The Applicants ( claim that the allowable bending stress is equal to .75 of yield. The 47
Applicants have decided they do not need to comply with this requirement and are using the allowable bending stress equal to the yield point (see page 23 of Applicants' Affidavit. The Applicants' only' reason for their position not to follow this requirement are the results in their Attachment F. The results of the tests do not defend Applicants' position, as will be discussed below. Due to an improper finite element analysis and inadequate interpretation of tests results (which has led the Applicants to believe they can ignore design requirement allowables), the Applicants have no justification for exceeding a stress ratio of 1. For these reasons, the Applicants should be required to meet the stress ratio criteria of no greater than 1, and all the supports listed in Table 1 with bolt interactions greater than 1 should be reanalyzed taking into consideration the comments shown in answer 7 preceding and answer 19 following. The test results in Attachment F to Applicants' Affidavit have been misinterpretted by the Applicants. Before going any further, it should be stated that the test information provided by the Applicants is not complete. Information which is lacking, for example, is the concrete test report, the mill report for the rods, information regarding the loading configuration, calculations to show the design capacities that are listed in Table F-1, to list just a few. In Table F-1, the deflection at design capacity is listed. The ! ; Applicants indicate the deflection of the tube steel for the different loading conditions. For the 6 x 6 x 1/2 zero offset, the deflection 48
- m - _ _ _ __
for methods A, B, and C exceed .09 inches at the design load. The Applicants have a generic deflection criteria which limits the deflection to .0625 inches (or 1/16"). The Applicants assume that the supp$rtconnectionsdonotmovewhencalculatingthedeflections. We now see that the support connection, which was assumed not to move, actually exceeds the deflection criteria by itself. This support point movement which the Applicants neglected in the design is referenced in the Affidavit included in CASE's Answer to Applicants' Motion for Summary Disposition on generic stiffnesses, on page 4. In addition, this deflection would be added to the 3/16" deflection discussed on pages 12 and 13 of that same Affidavit. For this additional deflection, the Applicants need to go back and recalculate the stiffnesses of all the supports. Method D in Table F-1 indicates that the design capacity of the connection for a 6 x 6 x 1/2 in. tube steel member is 2.45 k. The deflection is listed as only .01 inches, which still is not in compliance with the assumption fo zero movement, but is 9 times better than the method A, B, and C. The Applicants claim that the small design capacity and the small deflections are too conservative. I do not see where the conservatisms are. The design capacity, I assume, is based on a linear elastic analysis and is in compliance with Appendix 17 of Subsection NA of the .ASME Code. The elastic analysis requires that the material not reach r 7:he yield point of the material. This will allow the material to retain its original configuration after loading. (Also, see CASE Attachment B hereto, Regulatory Guide 1.124, page 1.124-2, under "Large 49
Deformation.) Nowhere in Applicants' tests in Attachment F or Attachments A and B do the Applicants demonstrate that the connection behaves in an elastic manner. Therefore, Applicants have not properly evaluated the test results and have not proved by the tests that the connection will behave in an ; l elastic condition when the load exceeds the design capacity.
- 19. Applicants state:
"The results of the evaluation of the conservative criterion, coupled with subsequent testing, reflected that with regard to this bending moment in the bolts, there is no safety concern with these connections.
Id,at 27-30." Applicants' statement is misleading, and their reference to a
" conservative criterion" is incorrect, as discussed in answer 18 preceding. On page 30 of Applicants' Affidavit, they state that this condition is not covered by the Code. However, on page 5-206 of the AISC Code (to which Applicants are committed in Specification MS-46A),
the commentary to the specification for high strength bolts states, in part:
"Because bolts in friction-type connections do not depend upon bearing against the sides of their holes, those provisions of the general design specifications intended to guard against high bearing stresses, and bending of the bolt due to bearing, are waived." (First emphasis in the original; second emphasis added.)
On page 27 of Applicants' Af fidavit, they use what they call the
" bolt interaction equation." This is a brand new invented formula which the Applicants have dreamed up. The AISC Code, at Section 1.6.3, lists the proper interaction formula for an A307 bolt, and that equation is 50
i i i l Ft = 28 - 1.6 fv 6 20.0 where Ft is the maximum allowable stress and fv is the applied shear stress produced by the same forces and not to e'xceed the allowable shear stress given in Section 1.5.2 of the AISC Code. Consider the following comparison using an external applied tensile load of 10 kips, an external shear load of 5 kips and a bending moment of 4 kip-in. on a 1-1/2" diameter A307 bolt. The area of the bolt for tension of 1.4053 in.; the area of the bolt for shear is 1.7621 in., and the section modulus for bending is .098175 d = .098175 (1.338)3 = .235 in. . Utilizing the AISC equation (and not considering the requirements listed in answer 7 preceding), the shear stress is 5/1.7621 = 2.837 ksi < Fv of 1.5.2 which leads to Ft = 28 - 1.6 (2.837) = 23 ksi > 20 ksi; therefore, the allowable tensile strength is 20 ksi. The tension stress applied to the bolt is due to the tensile load and is 10/1.4053 4 7.115. The tension stress due to the applied moment is 3/.235 = 17.02 ksi. The total tension stress in the bolt is 7.116 + 17.02 = 24.136 ksi. The interaction ratio is 24.136/20 - 1.21. This interaction ratio exceeds 1; therefore, the bolt is overstressed. Now we shall look at the Appliants' method (which is not mentioned in any Code): The applied shear over allowable shear is 5/17.67 = .283. Applied tensile load over allowable tension load is 10/28 - .357. The allowable bending moment, according to the Applicants, is (.75)(36)(.235) = 6.345. The applied moment over the allowable moment 51
is 4/6.345 = .630. Using the Applicants' invented " bolt interaction 2 2
.SR equation," the interaction ratio is .283 + .357 + .63 = .080 + .127 + .63 = .84. This value of .84 would be an acceptable value for the-Applicants, because they believe (as discussed before) that the interaction ratio should be less than 1.75 instead of less than 1.
This simple example demonstrates that when the Applicants are utilizing an invented equation, they have concluded that there is no safety concern. The ratio of the Applicants' equation to the AISC equation can be an approximation (based on the above example) of the values for the bolt interations that are in' error. The ratio is .84/1.21 = .69. This value of .69 corresponds to the Applicants' bolt interaction value of
- 1. Of the 155 supports listed in Table 1 attached to Applicants' Afftdsvit, 51 supports have a bolt interaction value greater than .69.
This represents 33% which have exceeded AISC Code allowables, based on this one simple example. It should be remembered that the values used were only for 70 degrees F. and did not include the recommended values
~
from ASME as discussed in answer 7 preceding. Although the interaction equation is as unique as Applicants' support configurations under consideration, some additional comments can be made. It would appear that prior to the introduction of the l bending moment of the bolt, the Applicants used the following equation: (T/TA) 2 + (S/SA) 2 = 1 This equation is the equation for a circle, where the radius of the circle is 1, and 1 squared is 1. As long as the bolt interaction i , formula had no additional components, it was similar to the combined l l l 52 l
stress formula for a weld. But this equation which the Applicants use deviates from the equation of a circle and the equation used for welding.
"It is interesting to note the Applicants' and NRC Staff's position in regard to this subject. This bolt bending problem was investigated by the NRC Special inspection Team (SIT), and their results are shown on pages 21 and 22 of their report (SIT Report, Staff Exhibit 207; see also CASE's Proposed Findings of Fact, pages VII - 8 and -9; see also 12/28/83 Board Order (Quality Assurance for Design), pages 62-66). The Applicants were aware of this problem prior to the SIT investigation.
The Applicants performed a finite element analysis (STARDYNE); calculations by the SIT indicated that the bending stresses in the bolt were 15 times larger than originally calculated (with shear alone). But the Applicants showed the SIT some preliminary calculations which indicated that bending moments were insignificant in all but one of 60 cases reviewed. This would represent about 1.7 per cent if the supports had been deficient. But now we have, as shown in the preceding, 33% of the supports deficient. This would show two critical points. The first is the Applicants' choice of a " sample" to demonstrate their position. The second is the Applicants' corrective action program. If the Applicants are not going to follow AISC Code requirements, the least they could do is to be rational about their deviations. The bending moment preduces tensile stresses, as discussed previously. These tensile stresses chould be added to the already calculated 53 5
tensile stresses due to a direct tension load. This would result in the Applicants' previous equation and still deviate fram the AISC code, but the interaction values would at least be rational. For example, using the values previously discussed (i.e., a tension force of 10 kips,' a shear force of 5 kips, and a moment of 4 in. kips), the applied tensile stress is 24.136 ksi, the allowable tensile stress is 20, the applied shear stress is 2.837, the allowable shear stress is 10. This results in the following interaction equation: (24.136/20)2 + (2.837/10)2 = 1.542 The square root of this last term should be considered (since this item is overstressed and the equation is based on a circle) and the result is 1.124. It is apparent that the AISC Code is liberal in its approach to the interaction formula, since the interaction formula for the AISC Code resulted in 1.21, still overstressed. The Applicants claim that there are no safety concerns because of their allegedly " conservative criterion." The Applicants, with this I statement, demonstrate that they can create a criterion which violates established liberal Code allowables, and believe that there is a problem that is generic to Comanche Peak and unique to Comanche Peah, J and when 7% of the supports which Applicants now admit are deficient by their own evaluations, but in reality 33% have exceeded AISC Code allowables, they say there is no safety concern. The Applicants are app'arently relying on the test results in their Attachment F when they make their statement (page 29 of the Affidavit). But as discussed above in answer 18, the test results did not demonstrate compliance with Regulatory Guide 1.124 and other design assumptions. l ( . 54 i t
- 20. Applicants state:
" CASE agrees that the moment in the tube (My) about the axis of the bolt cannot develop. However, CASE states that the moment Mz (which would tend to produce prying action, if any), should either be considered whenever the moment which produced torsion (Mx) is ;
considered, or both Mx and Mz should be released. CASE states further at VIII-6 that 'the ability to rotate about the local Z axis is inhibited; therefore, prying (moment coupling) exists.' Id,. at 31-2." I agree.
- 21. Applicants state:
"For attachment assemblies under axial loads, tnat is, subjected to a pure Mz moment, a finite element analysis performed by Applicants demonstrates that the displacement of the tube due to bolt elongation (along the Y direction) is safficient to cause loss of contact with the washer. Thus, there is no prying action. For pure axial loads, i.e.
loads applied to the tube steel betwt en Richmond inserts in the Y direction, there is no prying action and the release of the moment about the Z axis is the correct way to model the joint. Id at 33-4." l . To begin with, at the top of page 34 of their Affidavit, Applicants neglected to include the first'three lines of the statement of material facts, if that is what is supposed to start the paragraph. Since that information is not shown on page 34 of the Affidavit, I will assume that it does. belong there. j The results of the finite element analysis are not complete. The Applicants did not provide documentation as to the math model used (i.e., size and number of elements), so I cannot agree that the analysis is correct. The Applicants state that a pure Mz moment was applied in their analysis; this is not correct. I am assuming that the Applicants' model for the discussion of the pure bending moment is as shown below: i 55 e
. , , _ _ _ _ _ _ _ _ _ -g
O ; A e o Ut 7 ,, where P is an applied load and parts A and B are the intersection of the center of gravity of the tube steel and threaded rod. This coafiguration does not create a pure Mz moment; as one would expect there will be vertical net reaction (or tension in the bolts). The pure moment configuration was not considered by the Applicants. Applicants claim that the bolt elongation will cause loss of contact between the tube steel and washer (i.e., they have lif t off) I l and therefore no prying action. What they say may be true; I do not l know since I have not seen their calculations. But if it is true, then ! there exists another problem not discussed by the Applicants. And this problem is the additional moment now introduced into the bolt. Since the Applicants have not stated or provided information pertaining to the size of the bolt, I will assume that the Applicants are referring to a 1-1/2" diameter rod. Loading number 6 shown on page 36 of Applicants' Affidavit indicates that the bolt reaction is 20,000 lbs. The bolt is now being loaded on only one side since the connection is I rotating and is not resisted by prying action. The reaction on the bolt is located at point A shown below: 56 1
\
! /k 4? 4f 7 m ,:
This load being off center of the bolt creates a moment equal to the applied load times the moment arm. The moment arm is indeterminate due to the complexity of the problem. It could be located at the edge of the nut that holds the rod in place, or at the edge of the rod itself. I will ar some thtt the moment arm is at the edge of the rod. The resulting moment is then equal to (20)(1.5/2) = 15 K-in. The resulting stress due to bending in the bolt (as similarly shown in answer 18 above) is 20/1.4053 + 1!'.235 - 124 ksi. The allowable stress is, as shown in answer 18 above, is 20 ksi, per One AISC Code. Therefore, the rod is overstressed by 6 times its allowable for this unique design condition. It should be also noted that the Applicants used a tube steel member 4 x 4 x 3/8 for their analysis in the finite element analysis. The Applicants claim by inference that the beam is so stiff that up lif t can occur at the support point and no prying action occurs. But as I have previously stated, I have not seen the Applicants' analysis but there is a fatal error not recognized :y the Applicants. The moment in a 2 foot long member that has no end restraint (no prying action) is (40,000)(2)(12) / 4 - 240 kip inches. The stress in this member is (240)/5.1 = 47 ksi. The yield point for the material is 36 57 l
--p.g - - - -- - - - - - - - --
ksi. Therefore, the simple beam has yielded in the center of the beam and the end rotations have increased due to this yielding, and the Applicants have not considered this.
> I
- 22. Applicants state:
"A parametric study of the loading was performed to analyze the effect of bending moment Mz on the prying action which occurs due to the torsional load. The results of the study reflect that no prying action will occur. Id. at 34-36, note 13."
See answer 21 preceding.
- 23. Applicants state:
" Applicants have reanalyzed several support configurations selected at random assumirg that all moments would be released, as CASE recommended. The results reflect that adequate margins exist, even assuming fully released moments. Id. at 39."
On pages 37 and 38 of their Affidavit, Applicants discuss the consequences of the Mz moment at the insert, where they state " fixity of the connection results in higher loads on the inserts." And on page 38, they state:
"The use of th'e pinned assumption is normal structural design practice. In fact, the 8th Ed. AISC Specification, paragraph 1.15.4, states that inelastic action in the connection is permitted to accommodate end rotations." (Emphasis added.)
However, as has already been , stated, this connection configuration is not a normal structural design. Thus, the Applicants are off-base with that type of comment. In addition, the Applicants are relying on 4
- inelastic action. But the Applicants forgot to recognize that the inelastic action can only be for the bearing material and not for the bolt. The inelastic action referenced by the code is so that the fastener will not be overstressed.
58
.,_,.g. , __ . _ _ _ _ _ . _ _ . . _ , - . _
On par,e 38 of their Affidavit, Applicants claim that NPSI designers would check to see whether there were sufficient elongation of the bolt to allow for rotation. Since the Applicants have not provided any documentation to verify this statement, and I never saw any while I was employed at Comanche Peak either in the form of an original design or as-built, vendor certified, final design, the Applicants' statement is unsubstantiated. In Applicants' alleged Material Facts, they refer to several support configurations. Since I have not seen any reference to these supports or their calculations, I cannot dispute this fact. But I do recall that when I was employed at Comanche Peak one PSE engineer insistedthatweretaintheMzInomentsothatthesupportwouldpass the generic deflection criteria.
- 24. Applicants state:
" Bending of the bolt is not considered by the ASHE Code, because in conventional bolt connections, bending is not significant. In reality, however, bending can occur. Id. at 40."
The Applicants'cannot compare their unique monstrosity to conventional bolted connections. As stated in answer 18 above, the AISC Code does recognize bolt bending. l l 25. Applicants state: l
" Applicants have conducted detailed analyses regarding the ability to resist axial torsion. The results of these analyses reflect that due to the conservatism of the calculational methodology, bending does not present a safety concern with these connections. Id,. at 40-1."
See answers 18 and 19 above. l l 59 l l l
1
- 26. Applicants state: l "The results of tests reinforce Applicants' conclusion that deflect, ion of the supports at the design loads are very small regardless of whether the load is applied torsionally or as a shear, and that ample margin exists. Id. at 41-2."
r See answers 18 and 19 above. P h s o i t
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The preceding CASE's Answer to Applicants' Statement of Material Facts As To Which There Is No Genuine Issue was prepared under the personal direction of the undersigned, CASE Witness Mark Walsh I can be contacted throughCASEPresident,hs.JuanitaEllis,1426S., Polk, Dallas, Texas ; 75224,214/946-9446) My qualifications and background are already a part of the record in these proceedings. (SeeCASEExhibit841,RevisiontohsumeofMarkWals3 accepted into evidence at Tr. 7278; see also Board's 12/28/83 Memorandum and Order (Quality Assurance for Design), pages 14-16.) I have read the statements therein, and they are true and correct to the best of my knowledge and belief. I do not consider that Applicants have, in their Motion for Summary Disposition, adequately responded to the issuesraisedbyCASEWitnesskackDoyle}andme;however,Ihaveattempted sto comply with the Licensing Board's directive to answer only the specific statemnts made by Applicants.
~
/
(Signed)! Mark WalshJ
/
STATE OF TEXAS On this, the day of , 1984, personally appearedhrk Walsfji known to me to be the person whose name is subscribed to the foregoing instrument, and acknowledged to me that he executed the same for the purposes therein expressed. Subscribed and sworn before me on the day of , l Notary Public in and for the State of Texas My Coomission Expires: l
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CASE AT'DLCINENT B - CASE EXHIBIT 743 R:;virirn 1
. [p.g{#, U.S. NUCLEAR REGULATORY COMMISSION January 1978
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- OFFICE OF STANDARDS DE REGULATORY GUIDE 1.124
, SERVICE LIMITS AND LOADING COMBINATIONS FOR CLASS 1 LINEAR-TYPE COMPONENT SUPPORTS A. INTRODUCTION with the specified seismic event. thus helping to General Design Criterion 2, " Design Bases for mitigate the consequences of system damage. Com-Protection Against Natural Phenomena," of Appen, ponent supports are deformation sensinve because dix A, " General Design Criteria for Nuclear Power large deformations in them may significantly change Plants," to 10 CFR Part 50, " Licensing of Produc. the stress distribution in the support system and its tion and Utilization Facilities," requires that the de. supported components.
sign bases for structures, systems, and components In order to provide uniform requirements for con. I important to safety reflect appropriate combinations struction, the component supports should, as a ! of the effects of normal and accident conditions with minimum, have the same ASME Boiler and Pressure ' the effects of natural phenomena such as earthquakes. Vessel Code classification as that of me ,uppon J ne failure of members designed to support safety- components. This guide delineates levels of erviec related components could jeopardize the ability of the limits and loading combinations, in addit:on tu i supported component to perform its safety function. supplementary criteria, for ASME Class i linear. type Dis guide delineates acceptable levels of service component supports as defined by NF-1213 or' Sm l limits and appropriate combinations of loadings tion III.. as. Snubbers are not addressed in this guide. l sociated with normal operation, postulated accidents, Subsection NF and Appendix XVII of Section III and specified seismic events for the design of Class I permit the use of four methods for the design of Class linear type component supports as defined in Subsec- 1 I near type component supports: linear elastic anal-non NF of Section III of the American Society of ysis, load rating. experimental stress analysis. and Mechanical Engineers (ASME) Boiler and Pressure I mit analysis. For each method, tne ASME Code de-Vessel Code. This guide applies to light water cooled lineares a!!owable stress or loading limits for vanous ! reactors. The Advisory Committee on Reactor Code levels of service limits as defined by NF-3113 Safeguards has been consulted concerning this guide of Section III so that these limits can t>e used in con-and has concurred in the regulatory position. junction with the resultant loading:: or stresses from the appropriate plant conditions. Since the Code does B. DISCUSSION not specify loading combinations, guidance is re-Load bearing members classified as component quired to provide a consistent basis for the design of supports are essential to the safety of nuclear power component supports. plants since they retain components in place during Component supports considered in this guide are ! the loadings associated with normal and upset plant located within Seismic Category I structures and are ' conditions under the stress of specified seismic ' therefore protected against loadings from natural I events, thereby permitting system components t ' phenomena or man made hazards other than the spec-function properly. ney also prevent excessive com-if ed seismic events. Thus only the specified seismic ponent movement during the loadings associated with events need to be considered in combination with the emergency and faulted plant conditions combinea loadings associated with plant conditions to develop
- Lines indicste substanuve change from previous issue. appropriate loading combinations. Loadings caused ww w., , w USNRC REGUt.ATORY GUIDES ,_
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s by natur:1 phencmena ethtr thin seismic events, stresses should be calculated with the valuts of E and wh;n they exist, should be considIred on a case by- S, of thz ecmponent support materiti tt temperature. case basis. Allowable service limits for bolted connecdons are derived from tensile and shear stress limits and their
- 1. Design by Linear Elastic Analysis nonlinear interaction; they also change with the size of the bolt. For this reason, the increases permitted
- a. S at Temperature. When the linear clasu.e by NF-3231.1, XVII-2110(a), and F-1370(a) of See-analysis method is used to design Class I linear-type tion III are not directly applicable to allowable shear component supports, material propernes are given by stresses and allowable stresses for bolts and bolted Tables I-2.1, I-2.2. I-13.1, and I-13.3 :n Appendix connections. The increase permitted by NF-3231.1 I of Section III and Tables 3 and 4 in the latest ac- and F-1370(a) of Section III for shear str:sses or cepted version' of Code Case 1644. These tables list shear stress range should not be more than 1.5 times values for the minimum yield strength S, at various the level A service limits because of the potendal fo'r temperatures but only room temperature values for non-ductile behavior.
the ultimate tensile strength S.. At room temperature. S, varies from 50% to 87% of S. for component sup. The range of primary plus secondary stresses port materials, should be limited to 2S, but not more than S. to en-
** ** '**"I'"** * **#***** * **
Levels of service limits derived from either mate- the value of 0.65,. the increase permitted by NF-rial property alone may not be sufficient to provide a 3231.l(a) will be above the value of 2S, and will consistent safety margin. This is recognized by Sec- thus violate the normal shakedown range. A tion III, since XVII-2211(a) of Section III defines shakedown analysis is necessary to justify the the allowable stress in tension on a net section as the increase of stress above 25, or S . smaller value of 0.65, and 0.55.. To alleviate the lack of defined values of S. at temperatures above For the linear elastic analysis n ethod, F-1370(a) room temperature and to provide a safe design mar- of Section IH permits increase of tension limits for gin, an interim method is given in this guide to obtain the Code level D service limits by a variable factor values of 5, at temperature. that is the smaller value of 1.2S,/F or 0.7SJF . De-i i While XVII-2211(a) specifies allowable tensile PcQng on geme{ de sedon consMed b a net SCCU n at Pinholes in eyebars, pin-connected plates, stress in terms of both S, and S., the rest of XVII- or built-up structural members, F tmay assume the 2000 specifies other allowable service limits in terms smaller value of 0.45S, or 0.375S (as recommended of S, only. This does not maintain a consistent design by this guide for a net section of pinholes, etc.) or the margin for those service limits related only to mate- smaller value of 0.6S, or 0.55. (for a net section rial properties. Modifications similar to XVII-without pinholes, etc.). Thus greater values of the 2211(a) should be employed for all those service factor may be obtained for sections at pinholes, limits. which does not account for local stress and is not
- b. Allowable Increase of Service Limits. While consistent with NF-3231.1 and XVII-2110(a) of Sec.
NF 3231.l(a), XVII-2110(a), and F-:370(a) of Sec. tion III. A procedure to correct this factor is provided non Ill all permit the increase of allowable stresses in this guide. under various loading conditions, XVII-2110(b) lim. its the increase so that two-thirds of the critical buckl- 2. Design by Load Rating ing stress for compression and compression flange When load. rating methods are used, Subsection NF members is not exceeded, and the increase allowed and Appendix F of Section III do not provide a by NF-3231.!(a)is for stress range. Cnucal buckling faulted condition load rating. This guide provides an stresses with normal design margins are derived in interim method for the determination of faulted con-XVII-2200 of Section III. Since buckling prevents - dition load rating.
" shakedown" in the load. bearing member, XVII-2110(b) must be regarded as controlling. Also, buckl.
- 3. Design by Experimental Stress Analysis ing is the result of the interaction of the configuration of the load. bearing member and its material prop- While the collapse load for the experimental stress erties (i.e., clastic modulus E and minimum yield analysis method is defined by II-1430 in Appendix 11 strength S,). Because both of these material prop- of Section Ill, the varicus levels of service limits for erties change with temperature, the critical buckling e perimental stress analysis are not delineated. TUs deficiency is remedied by the method described in I"
' Regulatory Guide 1.85. " Code Case Acceptabihty-ASME Sec.
tion 111 Materials." provides guidance for the acceptability of ASME Section !!! Code Cases and their revisions, including Code 4. Large Deformation Case 16R Supplernentary provisions for the use of specific code cases and their revisions may also be provided and should be con. "Ihe design of Component supports if an integral sidered when appbcable. part of the design of the system and its components. f 1.124-2 } w, 'l_) b'lsk .J g .-e- 4- --Je - - --
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A c:mplita and consistent d sign ist possible ccly lar pl:nt c nditien, th strzssis cr Irds rrsulting
- hen w systers/ component /componInt-support interac- from the loading combinations under that plant condi-tion is properly considered. When a!! three are tion do not need to satisfy the design limits for the ;
evaluated on su clastic basi s, the interaction i:t usu- plant condition. ally valid because individual deformations are smtal. ' However,if plastic analysis methods are employed in 7. Definitions the design process, large deformations that would re-suit in substantially different stress distributions may Design Condition. The loading condition defir.ed "C" by NF-3112 of Section 111 of the ASME Boiler and Pressure Vessel Code.
, When component supports are designed for load-ings assogiated with the faulted plant condidons,'Ap- Emergency Plant Condition. Those operatir:g con-pendix F of Section !!! perr.a.its the use of plastle ditions that have a low probability of occurrence.
analysis methods in certairt acceptable combinations Faulted Plant Condition. Those operating condi-for all three elements. mse acceptable combinations tions associated with postulated events of extremely are selected on the assumption that component sup- Iow probability. ports are more defoimation sensitive (i.e.. their de-formation in general will have a large effect on the Levels of Service Limits. Four levels. A. B. C. and stress distribution in the sptem and tu components.) D, af se:vice limits defined bs Section III fer the de-Since large det,ermations always atfect the stress dis-g ; 4g . tribution, care should be exercised even if the plastic tions for components and component supports in nu.
~
analysis method is used in the Appendix F approved dear P *er P lants. methodology combination. This is especially impor- Normal Plant Condition. Those operating condi-tant for identifying buckling or instability problems tions in the course of system startup. operation, hot where the change of geometry should be taken into standby refueling, and shutdown other than upset. secount to avoid erroneous results. emergency, or faulted plant conditions. S. Function of Supported System Operating Basis Earthquake (OBEJ. As defined in
. Appendix A to 10 CFR Part 100.
In selecting the level of service limits for different l
,- loading combinations, the function of the supported Plant Conditions. Operating conditions of the piant system must be taken into account. To ensure that categorized as normal, upset. emergency. and faulted
( systems whose normal function is to prevent or miti- Pl ant conditions. gate consequences of events associated with an emer- ' Safe Shutdown Earthqucke (SSE). As defined in s . gency or faulted plant condmon (e.g., the function of Appendix A to 10 CFR Part 100. ECCS during faulted plant conditions) will operate properly regardless of plant condition, the Code level Service Limits. Stress limits for the design of com-A or B service limits of Subsection NF (which are ponent supports as defined by Subsection NF of Sec-identicsD or other justifiable limits provided by the tion 111. Ccde should be used. Specified Seismic Events. Operating Basis Earth. Since Appendix XVII derived all equations from quake and Safe Shutdown Earthquake. AISC rules and many AISC compression equations have built in constants based on mechanical prop- Svstem .tfechanical Loadings. The static and etties of steel at roon temperature, to use these equa- dynamic loadings that are developed bv the system tions indiscriminate!y for all NF and the latest ac- Perating parameters including deadweight, pres-cepted version of Code Case 1644 materials at all sure, and other external loadings, but excluding ef-ternperatures would not be prudent. For materials lects resulting from constraints of free end move-other than steel and working temperatures substan. ments and thermal and peak stresses. trally different from room temperature, these equa- Ultimate Tensile Strength. Material property based tions should be rederived with the appropriate mate- on engineering stress-strain relanonship. nal properties. Upset Plant Conditions. Those deviations from the
- 6. Deformation Limits normal plant condition that have a high probability of occurrence.
Since component supports are deformatiort-sensitive Ioad-bearing elements, satisfying the serv- C. REGULATORY POSITION ice limits of Secuon til will not automatica;1y ensure their proper function. Deformaticn limits, if speEified ASME Code 2 Class I linear type ecmponent sup-by the Code-Design Specification, may be the con-
- Amencan Society of Mechanical Engineers Boder and Prenure trolling criterion. On the other hand, if the function of a component support is not required for a particu. Venel Code.
1976 Winter Seenon Addenda III. Dmuon 1.1974 Edmon. includ.nt tne triereto. j
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ports excluding snubbers, which are n:t addrzssed cr the latest accepted version' cf Coda Case l herein, should be constructed to the rules of Subsec- 1644, tion NF of Section III as supplemented by the follow-ing:
- c. Method J. When the values of allowable stress or stress intensity at temperature for a material
- 1. The classification of component supports should, as a minimum, be the same as that of the are listed in Section III, the ultimate tensile strength at temperature for that material may be approximated supported components.
by the following expressions: '
- 2. Values of S. at a temperature t should be esti- S. = 4S or mated by one of the three following methods on an interim basis until Section III includes such values: 3* " 3S= ;
- a. Method 1. This tnethod applies to component where support materials whose values of ultimate strength S. = ultimate tensile strength at temperature t to S. at temperature have been tabulated by their man. be used to determine the service limits ufacturers in catalogs or other publications. S. = listed value of a!!owable stress at temperature t in Section III.
S. = S., f"' , but not greater than S., S. = listed value of allowable stress intensity at temperature t in Seenon Ill where S. = ultimate tensile strength at temperature t to 3. The Code levels A and B service limits for com-be used to determine the service limits Ponent supports designed by linear elastic analysis l , should meet the appropriate w c are r ate t S.,, = ultimate tensile strength at room temperature stress limits of Appendix XVII of Section III but tabulated in Section III. Appendix ! or the should not exceed the limit specifici.: when the value ht:st accepted version' of Code Case 1644 of 5/6.>. is substituted fer h. c.xamples are shown l S., = ultimate tensile strength at temperature t below in a and b. I tabulated by manufacturers in their catalog: or other publications a. The tensile streo limit F, for a net section as S', = ulumate tensile strength at room temperature spee fied in XVU-22:'+ ef See:;.m 111 should be ' tabulated by manufacturers in the same pub- the smaller value of 0 nS. or 0.5S. at temperature. lications. For act sections at pinholes in eye bars, pin-
- b. Method 2. This method applies to component connected plates. or built.up structural members. F i support materials whose values of ultimate tensile as specified in XVil-2211 be should he the smaller strength at temperature have not been tabulated by value of 0.45S, or 0.3755 at temperature.
their manufacturers in any catalog or publication.
- b. The shear stress limit F for a gross section as S, specified in XVII-2212 of Secticn !!! should be the a = S .,
3,, smaller value of 0.4S, or 0.33S. at temperature. l where hiany limits and equations for compression ~ S. = ultimate tensile strength at temperature t t strength specified in Sections XVII-2214, XVII-l be used to determine the service limits 2224, XVII-2225. XVU-2240. and XVII-2260 have S., = ultimate tensile strength at room temperature built in constants based on Young's Modulus of tabulated in Section III Appendix 1, or the 29,000 Ksi. For materials with Young's Modulus at latest accepted version' of Code Case 1644 working temperatures substantially different from S, = minimum yield strength at temperature t 29,000 Ksi, these constants should be rederived with tabulated in Section III, Appendix I, or the the agropriate Young's Modulus unless the conser-latest accepted ve'sion' of Code Case 1644 vatism of using these constants as specified can be ' demonstrated. S,, = minimum yield strength at room temper-l ature, tabulated in Section III, Appendix 1,
- 4. Component supports designed by linear elastic analysis may increase their level A or B service limits
- If the funcuon of a component support is not required dunng a aCCording to the provisions of NF-3231.l(a). XVII-plant condinon. the design limits of the support for that plant con. 2110(a), and F-1370(a) of Section III. The increase ditton need not be sausfied, provided excessive defleenon or fail-ute of the support will not result in the loss of funcuon of any of level A or B service limits provided by NF-other safety.rtlated system 3231.l(a) is for stress range. The increase of level A 1.124 4
\ u. n nw/ f}
, or B service limits provided by F-1370(a) for level D Stetion III divided by 1.7 should not be exceided for service limits should be the smaller factor of 2 or component supports designed by the experimental 1.167S./S,, if S. > 1.25, or 1.4 if S. < 1.2S,, stress analysis method.
where S, and S. are component support material Propernes at temperature. 6. Component supports subjected to the system mechanical loadings associated with the emergency However, all increases (i.e., those allowed by plant condition should be designed within the follow-NF-3231. l(a), XVII-2110(a), and F-1370(a)] ing design limits except when the normal function of should always be limited by XVII-2110(b) of Section the supported system is to prevent or mitigate the III. The critical buckling strengths defined by consequences of events associated with the emer-XV!!-2110(b) of Section III should be calculated gency plant condition (at which time Regulatory using material properties at temperature. Bis in- Position 8 applies):* 8 crease oflevel A or B service limits does not apply t limits for bolted connections. Any increase of hmits
- a. De stress limits of XVII-2000 of Section III for shear stresses above 1.5 times the Code level A and Regulatory Positions 3 and 4, increased accord-service limits should be justified. InB to the Provisions of XVII-2110(a) of Section III and Regulatory Posinon 4 of tnis guide, should not If the increased service limit for stress range by be exceeded for component supports designed by the NF-3231.!(a) is more than 2S, or S., it should be linear elastic analysis method.
limited to the smaller value of 25, or S unless it can be justified by a shakedown analysis. b. The emergency condition load raung of NF-3262.3 of Section III should not be exceeded for
- 5. Component supports subjected to the combined component supports designed by the load rating loadings of system mechanical loadings associated method.
with (I) either (a) the Code design enedition or (b)
^
the normal or upset plant conditions anu :21 the vib. e town bound eullapse load determined by ratory motion of the OBE should be Mgned within ;N.ll-4200 adjusted secording to the provision of the following limits: *.3 a = II-4110tal of Seeuon !!! should not be exceeded for component supports designed by the hmit analysis
- a. The stress limits of XVII-2000 of Section III method.
and Regulatory Position 3 of this guide should not be exceeded for component supports designed by the d. The collapse load determined by 11-1400 of litear clastic analysis method. These stress limits Section !!! divided by 1.3 should not be exceeded for may be increased according to the provisions of component supports designed by the experimental NF-3231.l(s) of Section III and Regulatory Position 5* 55 *"*I F 5'5 ***h d' 4 of this guide when effects resulting from constraints 7. Component supports subjected to the combinec of free.end displacements are .idded to the loading loadings of (1) the system mechanical _ loadings as. combination. sociated with the normal plant condition. (2) the vib-
- b. The normal condition load rating or the upset r t ry moti n of the SSE, and (3) the dynamic system condition load rating of NF-3262.3 of Section III I adings associated with the faulted plant condition should not be exceeded for component supports de- should be designed within the following limits except j signed by the load. rating method, when the normal function of the supported system is '
to prevent or mitigate the consequences of events as-
- c. De lower bound enllapse load determined by sociated with the faulted plant condition (at which i XVII-4200 adjusted according to the provision of time Regulaccry Position 8 applies): I XVII-4110(a) of Secuon 111 should not be exceeded for component suppons designed by the limit analysis a. The stress limits of XVII-2000 of Section !!!
method' and Regulatory Postuon 3 of this guide, increased ac. cording to the provisions of F-1370(a) of Secuan !!!
- d. The collapse load determined by II-1400 of and Regulatory Position 4 of this guide, should not be exceeded for component supports designed by the
, 53,,, ,,mp,,,,, ,,pport, are deformanon sensinve in the linear elastic analysis merhod.
rerformance of their service requirements. sansfying these eniena does not ensure that their functional requirements will be fulfilled. b. The smaller value of T.L. x 2S/S* or T.L x Any deformanon limits specified by the deugn specificauon may 0.7S?S should not be exceeded, where T.L. S. and be controlling and should be sausfied. S,. are defined 3CCording to NF-3262.1 of Secuan
' Since the deugn of component supports is an integral part of the III, and S', is the minimum ulumate tensile strength deugn of the system and the design of the component. the de. of the material at service temperature for component ugner must make sure that methods used for the analysis of the supports designed by the load. rating method, system com Table F-13.pnt. and
. .-l in component Appendin F of support Secnonare !!!).compaubte (see Large deforma.
gg gggEggggg non, in the svsiem or components should be considered in the XVil-4200 adjusted according to the provision of deugn or componeni supports. F-1370(b) of Secuon !!! should not be exceeded fc-
' ' 2" 142 061 1
e
c:mponent suppons d: sign d by thi limit analysis D. IMPLEMENTATION method.
- d. The collapse load determined by I1-1400 ad-justed according to the provision of F-1370(b) of The purpose of this section is to provide guidance Section 111 should not be exceeded for component to applicants and licensees regarding the NRC staff's suppons designed by the experimental stress analysis plans for using this regulatory guide.
method.
- 8. Component suppons in systems whose normal Except in those cases in which the applicant pro-function is to prevent or mitigate the consequences of poses an acceptable alternative method for complying events associated with an emergency or fau!ted plant with the specified portions of the Commission's regu-condition should be designed within the limits de- !ations, the method described herein will be used in senbed in Regulatory Position 5 or other justifiable the evaluation of submittals for constniction permit limits provided by the Code. These limits should be applications docketed after January 10.1978. If an defined by the Design Specification and stated in the applicant wishes to use this regulatory guide in de-PSAR. such that the function of the supported system veloping submittals for construction permit applica-will be maintained when they are subjected to the tions docketed on or before January 10.1978, the lo.idin; enmbinations described in Regulatory peninent ponions of the application will be evaluated Positiuns 6 and 7. on the basis of this guide.
- 1. : u.n
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,s_,,..,. , - , - - - - . . + . . - . . . - - . . -
^
.- ~~I t. PPA-29.063 r w FrHIBIT 834 TEXAS UTILITIES SERVICES INC.
~
OFFICE MEMOR ANDUM CASE ATTACINENT C To M.R. McBay - Engineering Manager ct.n' Row. Texas March 30, 1983 subict COMANCHE PEAK STEAM ELECTRIC STATION 1 1/2" OIAMETER RICHMOND INSERT SHEAR TEST Y At"tached is a copy of the Test Report on the results of the shear test on 1 1/2" diameter Richmond Insert. Based on the resul ts , allow-able shear loads used in the design at CPSES will assure a minimum factor of safety of 3. This is true regardless of the code allowables applied to the bolting materials. Per ASME - Appendix XVII Section III Division 1 Subsection NA
- Fv = .30 Fy A307; Fy = 36 ksi -
For 11/2" diameter bolt; allowable shear is: fy = Fv A = (.3) (36) (1.767)
= 19.08 Kips Per AISC Code Allowables For ASTM A-307 bolts Fv = 10.0 ksi For 1 1/2" diameter bolt; allowable shear is:
fy = Fv A = (10.0) (1.767)
= 17.67 Kips 17.67 Kips is the CPSES allcwable shear load for 11/2" diameter A307 bolts when used in Richmond Inserts.
Test specimen No. 7 applied shear load was stopped when the de-I flection dial gauge reached full travel at a load of 58,300 lbs. Based on the ASME allowable of 19.08 Kips, the associated factor of safety is 3.06 minimum. It should be noted that neither the bolt material or the concrete had experienced fracture at this load and additional load could have been applied. Based on the AISC allowable e t' 17.67 Kips, the associated factor of safety is 3.30 minimum with load being stopped before fracture occurred. l l l -
urrn-es,uu Page 2 of 2 This should respond to all concerns. If there are any further coments, please advise. J' k$ R.M. Kissinger V Project Civil Engineer i RMK/sgf cc: ARMS OL, IA J.C. Finneran 1C, 1A 'l
4 TEST REPORT SHEAR TESTS ON - RICHMOND 1 1/2-INCH TYPE EC-6W INSERTS MARCH 30, 1983 Prepared by Approved by J.C. Gilbreth R.M. Kissingtfr Civil Engineer Project Civil Engineer 4 4 I O I
TABLE OF CONTENTS i 1.0 RfFERENCES 2.0 GENERAL 2.1 PURPOSE AND SCOPE 2.2 RESPONSIBILITY 2.3 TEST APPARATUS 3.0 PROCEDURE 4.0 RESULTS -
5.0 CONCLUSION
S 6.0 APPENDICES ~ APPENDIX 1 - - ORAWING NO. FSC-00464, SHT. 1 CONCRETE COMPRESSIVE TEST REPORT APPENDIX 2 - - TEST DATA SHEETS APPENDIX 3 - - LOAD-DEFLECTION CURVES S 6
, 1.
4 TEST REPORT l SHEAR TESTS ON ; r RICHMOND 1 1/2-INCH TYPE EC-6W INSERTS I
1.0 REFERENCES
1-A CP-EP-13.0 Test Control l , 1-B CP-El-13.0-8 1 1/2" Richmond Insert Shear Tests 2.0 GENERAL 2.1 PURPOSE AND SCOPE
' These tests were performed.to determine the characteristics of Richmond 11/2-Inch Type EC-6W Inserts when installed in concrete representative of that used in the power block structures at CPSES and subjected to shear-type loading. The strength, deflections, and type cf deformations produced by this loading were the qualities to be determined. This series of tests employed only 11/2"-Inch Type EC-6W Inserts subjected to shear loads.
2.2 RESPONSIBILITY j The tests were performed under the direction of the CP Project Civil Engineer. Witnesses to the tests were: A Nuclear Re-gulatory Commission (NRC) Representative from the Arlington,
! Texas Regional Office, the NRC Inspector stationed at CPSES, a TUSI site Quality Assurance representative, and other site engineering personnel.
'l 4 e _ _ _ _ _ _ _ ___. - ~ - = * - - - ' - ~' ~
2. 2.3 TEST APPARATUS The arrangement and details of the test apparatus are shown on Drawing No. FSC-00464 Sheet 1, included in Appendix 1 to this report. The insert specimens tested were taken at random from the Constructor's stock on site and were; therefore, represent-ative of those installed in the plant structures. They were placed in a thick concrete slab cast specifically for these tests and which was composed of materials and reinforcement P similar to those elements of the plant buildings. .This is "4000-pound concrete" (28-day strength). The laboratory test . report on the concrete of which this slab is composed is in-
~cluded here in Appendix 1.
An apparatus for applying shear loads to the specimens was de-signed and built on site. This facility employed a 60-ton capacity manually operated hydraulic ram whose thrust against a crosshead was transmitted by tension rods to a 11/2-inch thick shear plate bolted to the insert specimen. Base reaction of the ram was transmitted through a structural steel grillage to the outer face of the concrete slab. Ram thrust was deter-mined by multiplying the fluid pressure (PSI), as indicated by a gauge on the pump, by a number equal to the ram piston area in square. inches. Deflections were measured by a dial indica-tor mounted on a remotely anchored bracket and with its spring-loaded probe in contact with the specimen bolt head or bottom nut where threaded rods were used. These instruments bore valid stickers showing them to be currently in calibration. 3.0 PROCEDURE In perfomance of the tests, inserts were cleaned of concreta mortar and other trash that would affect bolt thread engage-ment. The shear plate was attached to the specimen insert by a suitable length bolt or threaded red of type shown on the test data sheets, Appendix 2. A new and different bolt was used for each insert. These fasteners were tighteded " snug tight". On three specimens the shear plate was attached in direct contact with the top of the insert. On six other spec-mens a 1-inch thick plate was inserted between the shear plate and the insert, representing the " washer" used frequently at this location in pipe hanger installation. Shear loads were i applied by the ' ram by operation of the manual pump. As the load increased from zero (o), indications of fluid pressure (later converted to load) and bolt head deflection were read at regular intervals . These intervals were at 400 PSI on the pressure gauge, corresponding to 5300 pounds thrust. Load ! application on each specimen was halted before failure occured
- l
' and when the load had reached a size considered to be suffi-cient in comparison with the design load values. At this point in each test, the NRC Representative indicated his con-currence with this consideration. After this, the load was removed, the apparatus detached, and observation was made of the condition of the specimen.
.3.
4.0 RESULT 5 As can be seen on the test data sheets, the maximum load appl-ied to specimens on which ASTM A490 bolts were used ranged from 88.110 lb. to 95,400 lb.. The bolts could be seen, after removal from the insert, to be slightly bent. By measuring the distance of the bolt tip from a line perpendicular to the bolt head these deflections were approximacely as follows:
/,
F.astener Specimen No. Bolt length Deflection of Tip ' Type A-490 1 4 1/2-in. 0.0 in. A-490 2 5 1/2 in. 0.05 in. A-490 3 51/2 in. 0.10 in. A-490 4 4 1/2 in. 0.05 in. A-490 5 5 1/2 in. 0.10 in. A-490 6 4 1/2 in. 0.0 in. Other than these deformations, no bolt showed signs of inci-pient failure. Loading of the three specimens employing a double-nutted SA-36 threaded rod for attaching the shear plate and including the 1-inch washer plate produced a reverse curve in the threaded rod. The offset between the approximately parallel ends of each rod was approximately as follows: Soecimen No Offset 7 0.4 in. 8 .4 in. 9 .4 in. The fact that the end portions of rods were not truly parallel accounts for the difference in deflection measurec at the bot-tem nut on the rods. Although these deflections w ire expe-rienced, there was no sign of imminent failure of oither the threaded rod, the insert, or the concrete. There was small spalling of concrete around the top of some inserts. This allowed the top of insert to deflect laterally and in the case of Specimen No.1 to deform to a small extent. However, in no part of any test specimen did breakage or ccm-plete failure appear to be imminent. In each case at the time operation of the hydraulic pump was halted, the applied
- load was increasing, showing that neither the insert nor fastener had reached its maximum load carrying capability.
I _,.(
. 4.
The factor of safety for each specim2n based on these maximum applied loads is shown in the following table. FACTORS OF SAFETY
.. BASED ON
/
e I MAXIMUM APPLIED LOAD Meximum Factor o f da, ^efu Spe:i;nen Applied Fafener N w her Shear Eced 'a-* e.
, 4'ex. A:c!ied Les:'
(gips) sesign A//ows.k's i.d i SE,. I # = 3.3E
/
00fs.6/ ._ k 490 Bc/f g g,, 3 90.g
' ~,, = 3,4g W//" Shim A S 9 S.4 SSfjg.51 = 3.60 2 95.4 SSfjg 5, = 3.60 A490 A*If 4 .95.4 Nffg'St= 3.60 Yb /" Shim $
6 90./ S0*kg.st = 3.40 7 se.s ses, - s.:o 3A J6 Theesded
/?cc' 8 63.6 00*fz67
= 3.60
"//" Shin $
1 i 9 63.6 0$7.67 = 3.60
- Loaa' ha/ fed due to die / indicator for deflecfion hown.9 reached ife /km*/ of fravel.
4
- - - - . . , - - - . . - , , . . - . _ , _ . . _ _ . _ _ . - . , , , , . , - . _ _ , , - . - . ,.,w,.-~_ . . - -__.-----_v._y_.. ,rwv ..-,--__,y --,-..m.
5.
5.0 CONCLUSION
These test results show that the performan:e capabilities of the Richmond Insert in shear exceed the design allowable by a ratio of more than 3 to 1. Thts, a minimum factor of safety of 3 is indicated. The test resuits for the specinen: with the 1" thick washer are comparable to rne test results f;r the specine1s with- : out the washer. This indi:stes that the presence of the washer ' had little effect on the performance of the belt or the Richmond Insert. If additional bending stresses are introduced irito the bolt as a result of the pretence of the 1" thick washer, the test results show that it is not significant enough to distinguish the difference. i Based on this tett, the c'esigt allovables for shear loadirg are ( acceptable for use without further investigati:n or additional j calcu?ttions, t ' r I
8 e 8 APPENDIX 1 I r i i
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l r APPENDIX 2 TEST DATA SHEETS
~a
- Arr.:8dD/f C RICHMOND 1-1/2-INCH TYPE EC-6W INSERTS SHEAR TESTS "
REFERENCE:
CP-E!-13.0-8 J SPECIMEN NUMBER: / DATE d l WN w 4 BJ - BOLT SPEC: ,4 - Wd W/ SHIM PL. / W/0 SHIM PL.
,- DEFLECTION GAUGE JACK *
(IN.) PRESSURE THRUST NOTES - FAILURE MODE : r (P.S.I.) (LBS).
~
C.. s Og . /.'.a.C
. S S'
- . 2+ v: :
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. /t 8 2 fee 37 /so
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.EJc Jece 4% 7co 2 ?C 4000 .f.g sm
.300 44co S83cc SJ::.li >'u/d - &,4 ./-a -%d
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- syT Si [ ["' ~ '& W** '"
n .m.- n
- JACK THRUST EQUAL SHEAR LOAD ON INSERT .
JACK THRUST (LBS) = GAUGE PRESSURE (P.S.I.) TIMES MN JACK: EQUIPMENT NUMBER N C/r 606 PRESSURE GAUGE: M&TE NUMBER /88/ DUE DATE: , 7 b 83 e 2 c 94 DIAL GAUGE: M&TE NUMBER QUE DATE: 20 A #7 PERFORMED BY: WITNESSED BY: DATE 2.2s,~dfy f -Y kh& QA REPRE5UtTATIVE DATE I' M '.9)
.es. e a
w ._ -
~
.4P M NDIX 2 i RICHMOND 1-1/2-!NCH TYPE EC-6W INSERTS SHEAR TESTS
REFERENCE:
CP-EI-13.0-8 4 SPECIMEN NUMBER: 2 DATE dd -/#ad M.7 BOLT. SPEC: A - d 96 W/ SHIM PL. W/0 SHIM PL. V
.- DEFLECTION GAUGE JACK *
(IN.) PRESSURE THRUST NOTES - FAILURE MODE : (P.S.I.) (LBS).
- f. D M) 9fta $~ Joe
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.S*3 / C'b'CC 0 0, /C0
.fCo Evo
, y,;i~dCo Ccntu 2/ c . '.%isL ~ 4rr n'a,..c-~ Q i~ .
L 2 % .-r'-& m N ZJn, 4 *> J) - a,x a % 7 "< k n .
/ , o
- JACK THRUST EQUAL SHEAR LOAD ON INSERT.
JACK THRUST (LBS) = GAUGE PRESSURE (P.S.I.) TIMES /J. 2 f JACK: EQUIPMENT NUMBER /$CN (OC PRESSURE GAUGE: MATE NUMBER /82/ DUE DATE: 9 x< NJ DIAL GAUGE: M&TE NUMBER 849# OUE DATE:Ed A-4. 'e 2 PERFORMED BY: WITNESSED BY:
'd $N*Y.7 -zz e '
f/.h7s 4;..l k u 3- v) 1 ; DATE QA REPRESENTATIVE DATE
- stc."st w ts +-
RICHMOND 1-1/2-INCH TYPE EC-6W 8NSERTS SHEAR TESTS
REFERENCE:
CP-EI-13.0-8 o SPECIMEN NUMBER: 8 OATE 22 # M PJ BOLT SPEC: A - f- 94 W/ SHIM PL. V W/0 SHIM PL.
,, DEFLECTION GAUGE JACK *
(IN.) PRESSURE THRUST NOTES - FAILURE MODE . (P.S.I.) (LBS). P,$/S 9-00 SJ'00 0,DSJ* Bcc /4 G00 d, $16 / ECD /J~ foe - o,Ayo / 4to 24 El'c
. /f-f ECco 24, fee -
. / 75* 2s4:0 J/, Joe d07 220e .S% /00
.24 2 JZeo 4fe,Voo
. Sc9 Jcce n 70o
. 365~ esto is, oco 4/7 Y9t:0 fdJoe 463 A fte AZ &cc
.fC8 f2CD 48 Peo
.f./7 56 co 7f Eco %& *GCQ J.u.fl
. 6/2 &d 60 1 79 fee 66B 64cd MHoc
. ?Z.F G H t> C ft)/co
%% A;stZ& M m,u.
, M d J.~Q & D w=4 : .:. &
er'e.//A.a C.L. a ;. AM.
- JACK THRUST EQUAL SHEAR LOAD ON INSERT.
JACK THRUST (LBS) = GAUGE PRESSURE (P.S.I.) TIMES /_F, a r JACK: EQUIPMENT NUMBER 8CN 604 PRESSURE GAUGE: M&TE NUMBER MJ/ DUE DATE: f>_~ dy O!AL GAUGE: M&TE NUMBER Jeff OUE DATE: 0 h1 PERFORMED BY: WITNESSED BY: J t.' .VUb Y ]*l2-?) DATE
'il9 ;cx ftll {< _ 0I : 21 7,?
QA REPRE5ENTATIVE DATE O
R8CH'OND M 1-1/2-INCH TYPE EC-6B INSERTS SHEAR TESTS
REFERENCE:
CP-El-13.0-8 o SPECIMEN NUMBER: 4 DATE 2 2 Y/ 4** h5 BOLT SPEC: AI - 4 96 W/ SHIM PL. W/0 SHIM PL. V
.. DEFLECTION GAUGE JACK *
(IN.) PRESSURE THRUST NOTES - FAILURE MODE .
, (P.S.I.) (LBS). .
o.c oy 4pe .f ico
.C9 / foe /C,Cco
, e d.7 /2ce s.:C ? p o
.o7D / Cod 2/, da'
. /t'c Ecco E6reo
./32 2tec .ff, g o e
. /Gr 22'ra .9% tco
. / ') B 2det 42,foo a&? .7 c,o ec f7)'oc
.3of +tt s .rf m
. .T/o f4ps 18,3c0
. +'4'A f'8CD 64 80"
. r// S2 sc Gs,7cc f3L, 3* Wet '9 Eco 7 , % A ss.d Li. .x 3 6 n .
. S'7/ Ab o u 79,JDo .a4 /-- 2 .M M a.;c' 51,
.604 ' '
44tc 84600
. C <H., & Sto fc. /c o
.G66 7dco l ej g w o l Ce~ ~-s ae-u'M e. s'a xQ A
- J d46< w m . sin..- xf
- I
- JACK THRUST EQUAL SHEAR LOAD ON INSERT.
l JACK THRUST (LBS) = GAUGE PRESSURE (P.S.I.) TIMES < J. df l l JACK: EQUIPMENT NUMBER n'Ch 4 o (a l , .
- PRESSURE GAUGE
- M&TE NUMBER /82/ DUE DATE: ." .% " " #J f .
DIAL GAUGE: M&TE NUMBER 2d 94.4 DUE DATE: # # 1 ~ N3 l PERFORMED BY: WITNESSED BY: 9 .C' 3 -d ;$g'] p hre f C f.f' j.,-:y .yj l* h' ATE / O QA REPRE5EhTAilVE DATE I l l l -
RICHMOND J-1/2-8NC.9 TYPE EC-6W INSERTS SHEAR VESTS
REFERENCE:
CP-EI-13.0-8 ' s SPECIMEN NUPSER: [ DATE 2 2 ~9~ ~ 2 N.I BOLT SPEC: A - 4 96 WEHTM Pl. V W/0 SHIM PL. DgC OEFLECTION GAUGE JACK * (IN.) PRESSU9E THRUST NOTES - FAILURE MOCE (P.S.I.) ;
, (L35).
C, cr] 900 _ .(J'c0 _
,rf's /Ce I fe Geo _ __
. C 9/ /E60 /.f" f re N
. ./JL /6 DP 2/ ECB - __
. /d0 2two--
24.1co l _ _ 220 Edr! J/,Joo
. i(IS"' 2dff 37./00 _
.303 : Paco 4 2. 4 0 0 _
. 734, 2400 42: 7ec , _
~ ~
i 4 S-- 4 t'w .r.7, coo
- 3'f/ /r 900 fe, Joe 4/5" 4!6do &J, Coe
,944 SECD 6/ 900 _ -
~f*G DD c % . w 2 _ p df L n/f$'6
.#74 74,200 2
.$09 4*Cfd 7f,SDC 24 n b A_ /L.} 9ym
.b"]tt 64CD Bf 800
.S 70 Ctico 90./C0 l . -
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Mi _,Q dr d Jpeu.is r -' a .sA k.e & Ji-2.:: t J'4e c~~ _ M l l A s 4 r '~
- JACK THRUST EQUAL SHEAR LOAD ON INSCRT, JACK THRUST (LBS) = GAUGE PRESSURE (P.S.I.) 71MES /J. 8f JACK: EQUIPMENT NUMBER 8 CN 606 PRESSURE GAUGE: M&TE NUMBER /#d/ 00E DATE: 9 M b#? ,
af
- DIAL GAUGE: M&TE NUMBER EO9a
- CUE DATE: yEa 'M '85__
PERFORMED BY: WITNE5 SED BY:
.h. fN'/(bz(/ .5-22.h3 f,ba,. ja'n Q 3 u,;
DATE 7Y/Ek"GMb'hE D AT E ,, , e
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RICHMONO 1-1/2-lNCH TYPE EC-6W INSERTS SHEAR TESTS
REFERENCE:
CP-EI-13.0-8 s SPECIMEN NUMBER: 6 OATE 2 2 fa'" M # 8 BOLT SPEC: ,4-4'O/ W/ SHIM PL. W/0 SHIM PL. V
,. OEFLECTION GAUGE JACK * .
(IN.) PRESSURE THRUST NOTES - FAILURE MOCE . (P.S.I.) (LBS). o.o 39 9'oc S3co
.cc7 Boo /0,400
. C99 / Eoc /f, 900
- lJ 4' / C Ce 2/, 2-00
./ 72 2 sco 24, .6~00 2EJ' 24c J/,fCC
. A d,d 28ce 27 /06 Sit .5Ecc $2,4cc 4c7 .7&cc f 7,7de
. #At2 4eec f.j', o do
. a ,* s 44ee f/,JICO
. 429 '
e s'o c 6.9,400
= d 74 J'Ee o f*8,900 L M Ji.a2 i. aa Q'
.727 St<u 74.2co Jt'a- a.c M w ,.-c. &
. .~4.r C,cc a 79feo
.fe? Mco Br ace
.2ff 4*J<ce 90,/$0 ,
.- s m .uw<w ./.e ,s 4 l
l .%4 c,~sk ~ MM m M .~2 d s l ~ a-- Np pc -y .s, -
- JACK THRUST EQUAL SHEAR LOAD ON INSERT.
JACX THRUST (LBS) = GAUGE PRESSURE (P.S.I.) TIMES / _ P. d !. ~ JACX: EQUIPMENT flUMBER RCN 6 /> (, PRESSURE GAUGE: M&TE NUMBER /Bd/ OUE DATE: 9 A '# 3 O!AL GAUGE: MATE NUM3ER 2099 OUE DATE: lv A '/'i PERFORMED 9Y: WITNESSED 89: Gu?NU$Y 5'-22-f.3 }$A 1d'T.,97 ~. : O TREPRE5EniATEvf 34TE~f; p' DATE e e
m e w . - . a. - RICHMOND 1-1/2-INCH TYPE EC-6W INSERTS SHEAR TESTS
REFERENCE:
CP-EI-13.0-8 a SPECIMEN NUMBER: 7 DATE 8 8 #' O BOLT SPEC:d'A .74 doc / W/ SHIM PL. V W/0 SHIM PL. f;4g
. DEFLECTION GAUGE JACK *
(IN.) PRESSURE THRUST NOTES - FAILURE MODE . (P.S.I.) (LBS). 0.08/ 4co .$~ .100
.2 72- dec /o,4 00
.Me /dC0 As,9es 9] /Geo gf goo a $~/6 2LW 26,5K
. 56 8 24c0 34. Be'o
. 4 4.J~ E8De f 7, /Ce
. ~*J 2 2 doc 4E, raw
.st.' Jt co + r, res
. s.o -:eee S.c m
,- A= ?ce" l ft(5" 3 '.e./ ,,an p. *'r Tcia 4 m . -
1 I all M.,4-:L .Mm m .d%i& 1 %2 . - l
- JACK THRUST EQUAL SHEAR LOAD CN INSERT.
JACX THRUST (LBS) a CA'JGE PPESSURE (P.S.I.) TIMES . J. 2 J-JACX: EQUIPMENT NUMBER ACN 606 PRESSURE GAUGE: M&TE NUMBER /82/ DUE DATE: f , M , 'F 3_. DIAL GAUGE: M&TE NUMBER 849'l- DUE DATE: J'ddy *** '1# PERFORMED BY: WITNESSED BY:
, b, & Y"f A
cATE 3 - 2. = -13 & .# rLe ?.n.u QA REPRE5EleTATIv b E f
RICHMOND 1-1/2-INCH TYPE EC-6W INSERTS SiCAR TESTS
REFERENCE:
CP-EI-13.0-8 SPECIMEN NUMBER: 8 DATE 2 2 :97*'Mb BOLT SPEC: J~4 54 A'o/ W/ SHIM PL. # W/0 SHIM PL. OEFLECTION GAUGE JACK * (IN.) PRESSURE THRUST ~ NOTES - FAILURE MODE
, , (P.S.I.) (LBS). .
i 0 8d9 4 00 S~J00
./9e N40 /Os f*M
,34 7 /2ec / C oc
.+ef /4 cc 21, Coo
.4J 7 2cw EQ J'"
.fL6 4e e J/,8m
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. '7+:r 34 ea 9 7,7so 9/i~ 4 k <' SJ, m 290 4Pcc ff soo M n.,A:_ n ,A
.992. 4 6 ec 43f** & s&h!AL r 2.A d , M > k ' m n ed.
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- JACK THRUST EQUAL SHEAR LOAD ON INSERT.
JACK THRUST (LBS) = GAUGE PRESSUPE (P.S.I.) TIMES / 7, d'I JACK: EQUIPMENT NUMBER M' C N 4_ofo PRESSURE GAUGE: M&TE NUMBER //J/ DUE DATE: 9 3m_ Nr
./
OIAL GAUGE: M&TE NUMBER 2674/- DUE DATE: 20 _Juo . ??
,/
PERFORMED BY: WITNESSED BY:
- p. a.4+Lg 3e N . m a s. n ,,
DATi.~ na U7im hE cATE 1
.,_.___.__---.m- . . . _
RICHMOND 1-1/2-INCH TYPE EC-6W INSERTS SHEAR TESTS
REFERENCE:
CP-E!-13.0-8 e SPECIMEN NUMBER: 9 DATE 2 2 W d M FJ BOLT SPEC: JA -34 M W/ SHIM PL. [ W/0 SHIM PL. , I DEFLECTION GAUGE JACK * (IN.) PRESSURE THRUST NOTES - FAILURE MODE (P.S.I.) (LBS). :
.a 017 'YG C fD ,
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. )2 n / o ver /L Y" I 7 '7 i& c o 2/, doo
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- JACK THRUST EQUAL SHEAR LOAD ON INSERT.
JACKTHRUST(LBS)=GAUGEPRESSURE(P.S.I.) TIMES /.S. Er JACK: EQUIPMENT NUMBER A' C N d ol, PRESSURE GAUGE: M&TE NUMBER /dd/ OUE DATE: 9 km 't 7 OIAL GAUGE: M&TE NUMBER 24fV OUE DATE: M b 'n
/
PERFORMED BY: WITNESSED BY:
,G,6 Yekd S ~I A D , Y&v f0 b' .7- C'7 P.7 DATE QA REPRE5EftTATIVE .DATE
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- IL7.3 - A sing!e espansion anchor ustd to anchor an distance shall be twice the requirement of attachment Section shall be designed for one. halfgof ibc design strength defined herein. X B 5.1.14). i B.7.4 -. Testing (b) Shear: The designi ishear m strength
. B.7.4.1 Expansion ofanchors expans designed onanchors in accordance subject t if anchorage the requirementsof Section B.6 2.2 andthe d with m nthis muappendix shall be testeo to ser y edge distance requireme nt of Section strength Bit.2ta) sha or to determine the average test failure toad.
be satMei f Tests shallbe conducted by a testing ified byagency a other than (c) For combined tension and the anchor manufacturer and shall be shall certP B.7.1.!(a) and the minimum edge distance in accor-of theshear, testing program. the depth oembedment procedures.results.and conclu-sions. dance with Section B.7.l.l(b). - B.7.4.1 - The expansion mechanism of r I following methods: M .
~ /'
- talThe mechanism shall be actuated and test inginstallation by preloading:he enpansion anchor to
.\.s . - ' TU a minimum value as specified by the Engineer. ;
A L * *
" 5' '#" (b) be load A random tested to 100 selection percent ofof thethe installed required strength, anc
. J g 4 *. The testing program shall be established by the ll )
- g{.
Im Engineer. 1 s3 .'.' . .Jl . *.' /,/ D.7.$ - Espansian anchor selection l
< r
'l . The Engineer shallreview the espansion anchor design jt .t at-w .. q
- r N'* * ,.i . features, fa41ure modes test results, and insta!!ation (
@EM
~
procedures pnor to selecting a specific I ' chorage mechanisms shall be selected p , , . , , ,j'.] the e xpansion anchors are installed in the tension zones
*], * , [ 4 ,
l . O.
*j, ,j of concrete members.
=- /,
} , ,, /..1/.
..s
,s = D.8 -Inserts ;
, ' N* , n(-y., / !.r~rsv n Concrete inserts shalt be specified in accordance with
, . s.s W .' ,
** Section B.6.5 and tested in accordance f with B 7.4.1.
Q ,.
/
- w. B.S.1 - Design requirements Design allowables shall be based Theon actual test da 09 8 T t fypical details of espaasion eachets tests performed on inserts emeedJed in concrete.
ding con. tests shall cover the full range of possible loa B.7.3.2 llenan h3 testing # "' Tests shatt he conducted to venfy th'at the 8.8.2 - Strength wiif concrete reduction factor develop the steel strengtig of the espansionAanchor. 4 factor of 0.5 sh2U be applied to the average tes Design by test results shali be res'ncted to tests faalute thatloaJs are in determining strength requirements. representatne of the anchor spacing and load applica- '"" tion. O D *
- Grouted embedments shall meetthe arphcable Sirength reduction factors 6.9.1 and M D.7.1.3 The requirements of Section B 6 shall apply esceptFor ngsments W Seewns thatgeneral grouting purposes the material h .('
the 4 factors for espansion anchors shall be 0.9 8.9.2times the values specified in Section D 6.2 requirements for cement grouts used should to be inI accord with Chapter 3 of this Code. Special grout O.7.2 Atternatise design requirements achieve certain prorersies suchbas htyhigh of strength. l fe shnnkage, or espansion shall be fi thewns. respnnsi i For espansion anchors that dothenot Engmccrmeet the require-ment and srceified in the speisi ca of Section _ times the average test failure load. Y
. *4 S** * 'm ' Z * *
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! NucLtaa sart ry structuc ts cWE seene ponert) equal to at Icast 2.5 times the tensile stress shall reos esceed 120.000 psi. The coefficient of friction area of the embedment steel.To prevent failure due s a hall be 0.9 for concrete or grout placed against as.
tolateral bursting forces at an anchor bead, the side rolled steel with the contact plane a fun plate thickness
}h cover distance m shall not i.e less than: below the concrete or grout surface: 0.7 for concrete or grout placed against as-rolled steel with contact plane m=D _.Ir ., coincidental with the concrete surface; 0.55 for grouted 56 V/,'
conditions with the contact plane between grout and unless the requirements of Section B.4.4 are met. as-rolled steel exterior to the concrete surface. tb) Reinforcing bars with development lengths in ac. B.6.3 - Combined tension and shear l; cordance with the requirements of Chapter 12. for archor steel composed of reinforcernent. B.6.3.1 - For structural shapes and fabricated steel p.5.1.2 - Shear W e w eb shall be designed fer the shear and the flanges designed for the *ension, compression, and
" 8' (al For embedment steel of anchor bolts, studs or bars to control the design shear strength, the side B.6.3.2 - For bolts studs, and bars the area of steel cover distance m for shear loading toward a free edge required for tension and shear shall be considered shall not be less than: additive.
m=D f B.6.4 - The tensile stress area of a threaded anchor J= 7.5 Vf,. shall be taken as: unless the requirements of Section B.4.4 are met. (b) For shear lugs bearing in the direction of a free 0.7854 DO R edge. the concrete design shear strength shah be de. where D is the major thread diameter and a is the termined based on a uniform tensile stress of 4dyf number of threads per in. acting on an effective stress area defined by project. ing 45 des planes from the bearing edges of the shear B.6.5-The tensile stress area of Section B.6.4 shall be lug to lhe free surface. Dearing aren of the shear lug applied to all threaded anchors subject to direct tessile shall be escluded from the projected area. The e and shear stress. If the threads are encluded from the It tv factor shall be taken as 0.85, shearing plane the gross area rnay be used for deter. mining the shear stress. B.S.I.3- For combined tension and shcar, the depth of embedment shad be in accordance with Section B.5.1.1 13.7 Espansion anchors and the minimum edge distance in accordance with . Section B.S.I.2ta). This section provides minimum requirements for the . design of typical espansion anchors used in nuclear R.S.I.4 - Side cover distance shan not be less than safety related concrete structures end does not restrict mi). Under no conditions should the edge distance be the use of other expansion anchors pros ided the e span. less than the concrete cover requirements for rein- sion anc!! ors are designed and tested in accordance with forcement in Section 7.7. the requirements of this scetion. 11.6 - Desir,n requirements for embedrnent B.7.I - INsign requirements Stect
- Expansion anchors shall be designed to assure that the
*R.6.1 - Embedment material shan be defined by the design strength of concrete for a si en espansion an.
3 Engineer in specifications and design draw'ings. chor or group of espansion anchors is greater than the strength of the anchor steelencept aa rennitted in Sec. n.6.2 -The design strength U for embedments shall be tion B.7.2. This requirement shan be met by satisfying based on a manimum steel stress of 4 f,. The fol. the requirements of Sections B.7.I.I or B.7.1.2. lowing values for e shall be used: B.7.1.1 - Design b) anal) sis D.6.2.1 - Tension, compression, and bending . (a) Tension: The design puuout strength of concrete 4=09. I', shall be as defined in Section B.4 2 e scept that th'e 11.6.2.2 - Shear effective stress area shall be deGned by the projected i area of the stress cones radiating to*ard the concrete It6.2.2.1 - Structural shapes and fabricated steel sec*
- surface from the innennost espansion contact sur.
(($ tions and shear lugs face between the espansion anchor and the drilled 4 = 0.55. hole. Refer to Fig B.71 for typical details. The de. sign pullout strength of concrete sha!! be equalto or it.6 2.2.2 - The shear. friction provisions of Section greater than the minimum specined tensile strength II.7(as herein modified) may be applied to bolts, studs, or average tensile strength if a minimum is not de. and bars using a e of 0.85.The design yield strength /, fined for the espansion anchor. The minimum edge 5 . . _ _ _ . *~
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f 3 Fig. B.4-4-Effective streis etee for sadot*9e pulleet 4 A 4.7-Sereis eroe reduct'en for lia4ted Jeptl. A. a'r > ! 1 i
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seuCLEla S!Jefv StrucTWts,coct > 7 1 m Ardment - The embedment is that ste r I component B.4 a- 1)csign requirernents for concrete in contact with the concrete or 5fout used to transnut _ aprised loads ?o the concrete structure.TI.c e mbedmerit
,i may be fabricated of plates shapes, bolts, reinforemg bars. shear connectors. espansion anchors. inserts. or any cambination thereof.
Dransion sscher- A component insta!!cd in hardened B.4.2 - Ter:sion concrete for the transfer efloads inte structural compo. The design strength of concrete P, for any ancho e ments by direct bearing and/or friction. shall be based on a umform tensile stress of detf-Grured EmArdminis - An embedment located in a acting on an e!Tectise stress arra w hich is delbted by the formed or drilled hole in hardened concrete utilizing a projected area of stress cones radiating toward the at.
. grout to provide load transfer from the embedment to tachment from the bearing edge of the anchors. The t:ie concrete. efTective arca is timited by overlapping stress cones. by the intersection of the cones uith concrete surfaces, by Iniem - Commercia!!y available, predesigned, and the beanos area of anchor heads. and by the overan prefabricated embedments installed pnor to concrete thickness of the concrete (see Fig. B.41 and B.4 2).
placement which are specifically designed for attach. The inclination angle for calculating projected areas ment of botted;onnections. shall be 45 deg.The 4 factor shall be iaken as 0.65 for an H.3 - General requirements and loading embedded anchor head unless the anchor head is be. yond the far face reinforcement. In such case: a (factor t combinations I of 0.85 may be used. D.3.I - The embedment and surrounding concrete or I grout shall be designed for transmitting to the concrete B.4.3 - Shear I structure au loads used in the design of the attachment. The design shear strength of anchors subject to shear shall satisfy the requirements uf Sectiens B.3.1.2 and 11.3.2 - Reacdons on the embedment due to individual loads such as dead live (including vibratory loads), thermal. seismic, and accident loads shall be consid- B.J.4 - Reinforcement jg ered The loading combinations for embedment design If the requirements of Section B.3 are not satisGed, gbe in accordance with Secuon 9 2 of this Code. - reinforcement shall be provided to de selop the required 8.3.3 - Material and testing requirements for embed- strength. Reinforcement requirements sha!! be in ac. ment steel shall bq compatible with the material and cordance with applic.sble sections cf this Code and testing requirements for the attachment. placed to prevent failure of the concrete in tension. D.3.4 - The design strength of embedment materials B.4.5 - Bearing may be increased in accordance with Appendit C fo* B.4.5.1 - The bearing re strictions of Sections 10.I6 or embedments subject to impactive and impulsive loads. 18.13 shall apply to the maaimum compressive stress l B.3.5 -The strength of embedments as affected by the under the anchor head for all supporting surfaces where site and grade of steel, spacing, and depth of embed- VA,/A,is equal to or less than 2. rnent and any concrete dimensions which limit or re. B.4.5.2 - Anchor heads Lther than eose speciGed in strict the transfer ofloads from steel to concrete shall be considered as denned in Sections B.4. B.5, and B.6. Section B.4.5.1 shall rn;ei the require *ments of Seedon l P.3.6 - Plastic deformation of the embedment is per. misted for impactive and impulsive loading provided the D.5 - Anchora;;c requirements j strength of the embedment is controlled by the strength B.5.1 - Anchorage design shaU be centrolled by the of the embedment steel as speciGed in Section B.S. For these conditions a m_asimum duetil,tv rstio of 3 may be strength of embedment steel unless otherwise specified considered. The denmtion of ductihty ratio shall be as (defined in Appendis C. S.5.I.1 - Tension D.3.7 - Shear lugs that meet the requirements of Sec- Steel strength centrols u hen the desh strength of the l tion D.5.1.2(b) shall be considered effectise only when concrete P, as determined in Section B.4.2 exceeds the
$ located in a concrete compression zone developed be. minimum specified tensile strength of the tensile stress fQ t* een the embedment and the concrete and transverse to the directaon of the shear force for a given load cc,mponent of the embedment steel and fult load trans..
fer is accomplished from steel to concrete within the combination. depth of the anchorage by one of the following method s: R.3.It - A combination of bearing and shear friction (a) A mechanical anchor at the base of the tensile mechanisms shall not be used to develop the required stress components having a minimum gross area of shcar strength defined in accordance with Section 9.2. anchor head (incloding arca of tlic sensile stri:ss com-f, t
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NUCLEM SUETY STKUCi*gnES CCDE 3494 s (c) All concurreat loads. ,as specified in Section 9.2. A. l - Concrete ternperatures are considered. A.4.1 - The following temperature limitations are for (d) The coefficient of thermal espansion may be normal operation or any other long term period. The taken as 5.5 x 10
- per des F unless other values are temperatures shall not exceet 150 F cacept for local substantiated by " tests."
areas. such as around penetrations, w hich are allowed A.J.4 - When thermal stress is combined with the to have increased temperatures nm to etceed 200 F. stress due to other loads to determine a design stress, the magnitude of the design stress must not be less than A.4.2 - The following temperature limitations are for the magnitude of the stress due to other loadings alone accident or any other short terra period. The tempera. 1 unless the foUowing are considered: tures shaII not exceed 350 F for the surface. However, p local areas are allo *cd to reach 650 F from steam or ! (a) The effect of cracking in the tersile ze.ne of waterjets in the event of a pipe failure, g flexural members on reduction of the flexural rigidity ;. and on the redistribution of stress. A.4.J - Higher temperatures than those given in Sec-(b, The reduction oflong term stresses due to creep, tions A.4.I and A.4.2 above may be allowed for con. crete if tests are provided to evaluate the reduction in and
, strength and this reduction is applied to design (c) Stress combinations that reduce the magnitude of allowables. Also, evidence sha!I be provided which the stress due to other loads utilizing actual tem- venfies that the increased temperatures do not cause peratures and temperature distnbutions which act deterioration of the concrete either with or without concurrently with the other loads. load. J APPENDIX B - STEEL EMBED 51ENTS '
s B.O - Notation B.1 - Scope a = dimension, out to out of bearing edges (see B.1.1 - This aprendis provides minimum require. Fig. B.4-2), in. ments for design and anchorage of steel embedments A, = reduction in projected area, sq. in, used to transmit toads from attachments into reinforced 4, = loaded area. sq. in. concrete structures by means of tension, bearin,g. A, = maximum area of the portion of the support. shear, friction, or any combination thereof. ing surface that is geometncaUy similar to and Tvpical embedment details and concerts as referenced 6 =d * *EE*" *" ""
- en on. out to out of e e ges (see Fig. D 4-2), in. In addition to meeting these requirements considera.
D = major threaJ diameter of threaded anchor or tion shall be given to the efTect of the forces applied to nommal diameter of anchor,in. the ernbedment on the behavior of the overall s'ructure. ff = *pecified compressive strength of concrete, psi B.I.2 - The requirem nts for the attachment to the f., = minimum specified tensde strength of anchor embedment shall be in accordance with applicable steel, psi codes and are beyond the scope of this appendix. f, = minimum specified yield strength of embed-ment steel, psi it.t.J - Design limits less conservative than those 4 = overall thickness of member,in, specified in this appendit may be useJ by the Er:gineer L, = embedment depth for tensile anchorage if substantiated by experimental or detailed analytical measured from anchorage bearing surface to investigation. concrete surface,in, m = minimum side cover distance from the center B.2 - Definitions o an a or to the edge of the concrete.(see Ascher hrad- A nut. wJster, plate. stud. or bo't head n = number of threads per in, or other steelc mponent used to transmit anchor loads P, = design puuout strength of concretein tension, w the c nce by hams. th Arracherer -The attachment is that structure e sternal U - e rquired strength. to resht fastined l.u.Is. lb to the sui faces ot' the emtiedment w hich transmits loads e
- ttrength reductmu fa6 tor, daarnu.when t.* the cr+cdment.
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( ar _ *3- .C I. t
-+= a. : + . . .. n .r n h, i, . :
E a
. n, - :1
- . _g a, a. n'
- E 3 .5-..
- s , '., ~1-8
- . .ee-z -:Iw Ik n
,7 $ !'g' f i E
- - s --
E
==== k-7 (C-sE{s-tC 1 5 E F -'
ttte 3 .2 E, *
; p .- t.wp
,- 2%ska s y 6 s-- g***
.s:s aY s* L= w .
s. IEthL
- e. r s 1 E 35355 3 4/aee .s s i alsi 4 2,a
} ._
J- t6 526t l I.. . 4 4 .{. :
.u
-.= = ----fit 5 6 -
I h5 ', h5 , 3 I Ij.,.i ~*** 5 IEE* !a. 2J; 3 2!'.:
- g-I l a,I-E,h u
g -dgd - gg Sfs3, - gggg -2 -. g t gaz* 3 g ,4 L ,,,, 3: pgaps - 5 ea , gpgp g gypg g.** E. m ,bak s a s ss , ,,,, .! 5. *,*
,,,, E, -u I. .
i l. i l. l k. -
- u. m a a. - aal: - ils sg ,e j _.
- : 5iI t !; u
- e. L-
..L i-i l
1 : , ,; m e a ssE e -__ ;.^ 8
- =
t, s.4. 4. s.. L l ,
- E. 4,;
a 8 4 ta.r . Et4;;2 -' E! : = ff 20 "aLLLL
* .. .. ,s tutt' st '4l.= ,is 3*83 d, f - g-:
.~..-s 7:f g. 4" s
gl3, 4 4 ,e ,r E, .n --== _a,_ astt:t -
--g ,f 5, ,5 5 .t*
I
,5.i.
g=3 -
.nses jiss' s i.
1
-3 I:4444 efijs E E* IEEE -13 l.'I .*
4p*ifft 6 55i3 3 ELL: *T-
'l b Ig gg
'Igli gift 022 w=u l *$& :4*
1 LLLL dl 'li l l f La s LLLL 444 l 3:4
....s...
't-. .. --4'TW'._
- - qs ' xgh n t
_y-- -- .
.,.4 gr v .
,,;v. . , .
,__3zy ;p--
.f.m_ ~
l l
A .- 'a C-
.. s
,-w ,, % -a L . * , .- ; , . - 4> . .c 4 ! -
N **-' -- h hn ,e m,$ x,,P:Ut{ ..m . - ',._~ . . .eU;w ', . . f mTf-
~
n' i Q. , - 2-
;a.a A:m.s. N.d. - .u s.Y,
, . . . . - - . 4L m_ .
s, -._;.y
._,,a._..,,.
. .._sy .;
t ew . - . e - . w ._ e ,. . .o m e.s - __ z ' a s _ "- T'r2r-- 7N----',_ --,
- y s ' : =
a Ia- .ccC -C :' u:=
*u = u 9 - = e a = = .=
3 ,-= 4 2
-2=.= 3 = =. c c= y *
; .u. =z : 9 -. -;ps 'u:-:
., 5 = 6, .== =-is
- =c =-
5
*c 6 - - : u2 3, 2
- r. c t = . i . m s .- = 9 .C ==i-k;=k- -
.o . .s s . , .: * .=-.E
.; =: - -
.= = 2.== k=t x
.k~5, u y cnx"=5 ksu-u u s=s
-s -s k ,.
-; . . =- -
- v. .s x .-
. ; -s .=
u ,k
- c -o u s, o
,=u- 2
=-
k
~===
i,,-= - 3.c c e
--m 2 - . =
.=- ., = 5,.. '*
..c.=
u H 2 ; *; { =c - *f=. s;g i =$g k5 if 25
. -Mg: - W.
E u.== c--.2
.= u*pE ==w 2 :5 u{t!L=
= = '5 9 3, g-
! 1 5 =2 .y, : E
? '2 " 2 .,G = =E
*2 =L 3.5 In-2 7 = a .E r ,
.= u. kus: u_.==.
_==g=kE. =- 1. .al ,M ,gs
= c = t . --
- - 3, 8 l I ; g .= - C 7 - g 3 s_: 7iggW=I 0 nE933 15
-5:9 = g. n g ? 4=!.
- E 'gEd ji .= 5 ! ! $a 4 ' 8 ye i2
.x 5=k e=. . -
s 3-u, 5x == uuc _u , 1w == =. = == 6a2,-
., a
==uk Cu 53 '- =4, "-
=
= - .C = 5 h i , 5 * -. .3 t.
9, / E *; k u -22s E k .I. '= If e ,. =E k - =-u. .I. 5, e.
, - -.,s, - - ,-.=- u 5; = c =) t ., - c.
u
. =, y , = =z . .=ou -2. = - .
3;ss: 6 _u =- r u- 7=_ 22- u 5 - a, o g g .s=-=,*n - = Y a z.Le == ,2k w. E = _.- u "I g m2 u z
=
=w < t -
r 5.a* m e _I.J _5 ,e
=' -M,-u , a = e ,E
=,.*-5z - 9 .g i E .=ik$z $ =
E se : a 0 - I j . 0EI .E E E n-O f_ v5 v k k.! o5 e*, u- u== ., .-=-u-o=.s s >3 _=._ = : =k o
.c _ = == :,g.
- 7.e =.
E
- s7 = = =. p .ks a Fwo: -Jh=== 5=eju s sg
- s c=;, .,s=
- u ue
%, _y ,s _3=2 g us s a 9 , , ;.-- e x o - =, =- = =- = . , .: ,.
, .r : -
a -
.t a
2 =. 5.= r k = = - C C: a s.= = = 4 Mi,s-cw-
= - =z .i pz=, 5. .I 2 = ,k
= c. s =., _0 f,
.'a n a aka"u a-.,
a .: 04c
- : 7h 95 gig = sesma : ... sos a es .o .f.w.sas . essse.nos sweae as y x 't : *--
3 , z u -
- i g =
g 2
$ e E
.- * [5=g ?
4 : 30 - 2 o. ck. :18=k _= c 7 s c 5 2 = 9 "x26- = = t : =k-2
- 2 ---
.j I 8 a k=45# T 54 : E
.l g g5: - y gg:
, -, s t ==- 3cu ,,4 ~_ ' E,-E ,, _s nE-
- z. = - s,uo=u-
- l' .t - x ,-
o = i g 2
* =5e-
- c.= =u-
- Em
-uf
.. a
= .=.I
- ,.I s - : S=c m=,c 3E g - - . . - - . i =-k E uo..k _c '. w..: z :.
..*. . l I ft <o =.=-=
y _= 9;- .==u u O=
=c=- 1 .-u=-."-
I o C r
" a -
3
) i.2 .( o>=;52 . >-
38 1 x= 5 s .k i = < = t C.- /
- I, . '
l I$ i :f 'E & 7 ' ~ - 0 I =e >
-- 5-a -Ec I
. l i
EEe 9 ,I = =L ken,9=r-v .:..s k. - -
-E. , := =c -
,(:uk-
% 4 g ., - au
* - 4 3 e ==J --
. = =-
4
! : e .=g ! s :a t .! ,0 4 ma
+
-I
, t .
- .. = .5 - ==__,_- . z , =.e I
A 2 ; , =- 2s ! = E 5 5 & i, < 1 ' i!
* ,l }1 -, ..
4 x .= = =
- = 3 3 5 , o;- -=s -
= m=sr i , e . e o = = .= -
- ,= .,x k , s k=u =--<,,y l ' m- y s -s m p.:.-=.us.J c l g m2 =>s = s:=>.3r. s 3 z-=>
- - =
t ,
=c I ! ! ! l ! l 0 9 EIldi;"i. 5 3 :4 s.u.% a... 3 .u.a..s aussa .es ao-.e n m s--. o g3 ma m , . T=3 -4==:= 4 l
1 I
,5 , h E- .Nl
_ _ , ..-_'4 .
.' . e ~
m ,_ -
* - " * " ' - f' l*bb?Ribb5k.
I
,N
,, ,g, ; 7"4 , ., +.. .- ,- .,r..- -
t . t ? x .# . 4 ' W ..q.: % , ,, . , ,;' ..;~-~ k c .1-
--*_m-=.
-a~--..--
=~ ,, ,, _ - -
3- - - - _~ n - - . - _ . . - - w-__. _ I I b l mem.. . .ip a. p, a. n 4 up.4e s6n .... p. .ames,4 . s3 py ..o nog 4 E'i Il l E C li 2 .*. 16 e4 s0 s1 501 RBI IE SE tPJL 5'O && eM uc. t i.I L9 uE Zs ton us e4: li Zv teu e6 p tl IE EI 13 et maa h5 1;l *A4 GP.LF k
' ' 00 TE 91 t'A l 18 t*.it C w 11 e.I l e4?
in.uma om. .i : t'est t pa.6..m .mios3 ,mios3 : in.u.=s
=. n e ., . . ,mw3:3 t ..n y s i m.1
,,,,,,,g, ,,g,,,,,-
.i *al=" . .r....
,,,,,,g, --l,,, ,,;
- .p n.. ..
i .ii i .r . : p.ri eig se 6.n P.
**= u = 3 p.cpue:g ..ac . w y us,
. ieu .
on.i in.winna miaalow t.owin i gag p,= un.usu.at ga s y . . . . ii 3 synsea 4: 44 Aap.g je vosopen go susp!geos pus uogogasp peopuols qiseq. wigs-g y 31gyr j ;; ;. , y
~43D_g fv T*+, .: Wh~ *M <,; Y4, c NL .-
t.. so. 3 = sie . i w,g ~* i q.y
'y . . . D.p*T.'
s
' 4. . . '
--m 'i ;~ g o
.~
t l1'.i .9,.w- r - a
.) g E ~
=
g S 2 f
. ."- . ;. . - ..., 3- g , .
wt
'j T ..,# -
n- - - a
'-'. r : * .. . . 4
- 9. ns e. : . , ' g
. r34 .
N J iyg 3
, , 3, .. * &
2
'. y
@m e
\~ ~ J - g--- . ...a J 1,', -* 6.
a . i [ a L n.,
'. D' ' dy", U. ,C.
*7 .*r h e, f:i i 3 k a,i 3 . , ,
. s }'. . , I, , *-, / ; , 4:;. ; , j f "oA-- . jM k\b l 5 4 , e"
- 7 ...k....t....
!? Jr' c .-c.
-l,'1:l' }; L . A_ _ '
i M.* .' 4. 5 ~.
, . . y9 J.* *n - n~
(
-{
, 2
.ns v . s' , 3 2 J 9., P l
*1
; i i; 4 % N ,
4..,s ,
%. , .f' ? s.$ ; ;!D l ,.
2 Ifi 4',,.,2. .y .. i g 4. g- . s ,g e g;
., ji R _g s e ?* -E b5 ?*
< 1 4, k
~1
-- ~
m
- e. a :-. ,s P2 me s E b 6
- 9$
. .e m.
8e e e
......-r,-e g ;
6 a
I c . . . ,y _~ 4 .J s. v ;, _ 3y . * ~ *, . ' .; , q . ., . ' p z . ' < , l,' ()$ ; _^ ..j". .l2 w m. s 'f [' :'- hh . S e .g. 4 ,I -7
. . s. ...
. =wwmac
?
p , . . * \ ' -
- s :4 'E , 3 ;4
.=$..d[.,\. ,s 1
A l'. .u 1 . N., ' 3 i
} .f ,48 e a , ($,
! , ,'i s' ;- !
a(..
- w. ;
it - e' -
-" {,)!/a )\
r : i i t
,. g
&'l't ,.
.; 4 g
( j 8 j' jy * \, , , .I
,- d ,'S ;j-f h' .'e; 3:, -
I
.j)!.'!.,d.$. fd.)dd,,
~l T ,b
.A's ., i :
CC, }} = __ _ m _
~,k w p, gp y e ;
.mo g
.a :
g*x g g.. .. -..
- p
.i
%xm ~g . m. m emi
,:- . t..p t p ,j
.sat
. : -oc. -
,a
,s . l l i NDid,?"}$L !!!.
l HIE 5sier!l.!! ANgd
!$$$[#dh M $ %4 g n g*Q,* $g g , y *
*.g ,
l - .a- I y 1 wr--M. r- " m *rt- - '
3 RECENT STUDIES IN NORTH AMERICA ! l
; Afect a Icg c of about 30 ?rass, the pullon tests base agaisi l
,, innr inso engir asul a number of p.atenes hase feris iden in g i i
- g i s.nium ammtrics in roemeaiun with these acus. In North e e 3 Anwen a..l(ic h rdsw l .n hern advocating elese ecsrs on uo mimal son-3 3 <rese nwn'ihert klallioirap h.as alw Icl missed slee esse of thew teus ' '
'l A in C m.nl.a. In umhes sc)werted by Alathoira." hmeuonc vomrete - /
'l l, smreing a somincune sineitgth sange hom volts to SYND pu (til so [g 422 kgl's m2 ) at 28 dass was investigaint lle pullone awmbly son-l ***'*'"*'~ / i
{ snacil of a higle usength ucci shalt n.7's in (19 mms in ihanwacr anal p 'f
= '-
4 eed seien - g , 7, ) ! I.2', in (In7 mni) long. sogether weih a 2.25in. (57 mmt ih.emeter amt gen- /
/
2 l 5 /' a I/M in. (2.H smn) thitk w.nher as the emhnldctl head. 'I he awetnbl) w.n hcht in guniiion in 2 x 2 x 2 It (filo s hin x Gininm) ummlen enoids g j )*
\ /
j f h3nun aint w.nhers as shown in Fig. 4.1. The critical dimemions were \, ,, / ' " #'""' ! o etw etiameter of the washer that was so asa .n the embcildcol hcast aral V 8*tts= meam li the elisaame lenween the top of this washer ami che indite of the 2 n =tosa tst a==l
^
- ! foinmoil. This distame was Lept comtant at 2 08 in. (55 mm). The l ...,,,,,,,,
j l ucci shaft armi the emledited head were pulled out of she hardened e, - i
, emwicic by means of a hollow tendon ram esciting pressme througle
) l a secci sing heasing plee with an imide diameter of 5 0 irs. (12611 mm) !
Fig. (2.sneidi shewho she e louve me.ieu esid dinies leas of riie e% l l f ami a thick..ess of 0.5 in. (!!.7 mm). The indde aliameter of the lacar- beoe6ae pleie and the embedded hood. (Feem ed. 54.1 I '
] a
' Nese is taperience lad cetes thee the obeve dimensions are mese !
J
^
* !' I soweble. !
r J Nose 2s Iosel etse "A" of teaves surface of a frustrum of e right l tirsulet some is equel se
'; ' I. l.* -
s r.1 l A = elld.a + dJ j
,tdi f.,,.
w.e
+
} g =. 5 = v W + W. a - d # ;
d 'l 1
'I sub mweias fee 5. d mad d. we est :
j d 9 ' l A = 2040 in.' titi.e smi i l i- B. .i ._ .
- 1. . . .. -- . .."r l .-- ,
l (, ' p'g ,
, p iiig pl.sec. the outside diameter of al e embedded head, and the diuance i
u . * - henicen ehem controllett the siac amt the sin angle of the conciese j A ;. b5 d 'd hmnimi to lac pulled out (Fig. 4.2). A womten mohl with pullout I 4 i hA j$ - " i 6 . awmblics installed is shown in Fig. 4.3. The carious stages of a pull. { i j' l ' ; 4 out itse lecing pcilormed as ile Can.mli.m hiines tiranch aie shown in : 4 Fint i1-18. 1, ~ i '
) D ~ h T}pital test resules for shc [milout tests are shown in Tahle '
1; l - :r 4,i ,
' - ' ,E ___~ -l.l. aew] the corielations liceween ruinpeessive avul gnallout stiesigihs l l;.
are simwn in Fig. 4.9. l i, f.e 4 t- A pwlieve enembly woh 0.75 4a. s- Il9-mmi plywood form, eo eshe, Tir comimions ocashed h3 Alalhotra" were along she lines ] I woh one.eled.d . . ene.eh, the d.em e, of she ik,eeded shof, .e. O is n sa. fi 9 mm (f rom Ref. 541 scia sed hv Tecmpri esecpt sh.it the imlbmt ecsts weie repialls al* ' l I
- a h IM b e- M *um@<ened !
! l h up
. i l
t1
~
! l
- h l
kk ' n tamm JtaMas n%waac. s.a .a. .hmtea. . 42 a ms.a.
, ..=
3$d$$$Jf.h
.e -
.. w.mtv - : w.m. .s - .a.,a -== aw v. .
.a .-
=
s
=a3 I
=
c .5=.5 zs ?- =e =~
=
* =.
E. = . -c I'5~
,,. .a. .:
..- h9.- E ==
=- m u e4 . . - ,
- . =- *44m E E.
- z-m 5 L a C * :. 2 A =
. 2 E. :. =- M A L
= . 4 c. = - g E k=-kc
- _= E= _3. =
- .3E s,e :e -2 =. ;-- t @=
5 n6 .2 - o r. o-=. t -'
= - . . .s;m.
5 x s .. : a , a-
- m -.
=- **e..r ._ z
- an =5 .
x=
. =S#E 6- E- 3
= 1 :-
_E~- .: 9
- . - .9: = 3 5a-*-
* "k-=u:- 3E.
zz Ma.< r _. E e _ =- 2 :=. s-
==-4 z k. . .
.-n a :.
s : e s2 =. .- = .= u
,- - r. -.6 .
6 ., -- e
-_x_
a f_ e =. n - 8= n
. "0
- rn E:= 2== 2
- ~c ~- e
=
S *r 2F .- " E= 4 2 .: a -: 9 : o~e=_= r4
==k Ye s .,
=
- i. d .* 2 a
2 Eu4 ~ 3. ' Se = "=. O r g == == a g ; 2 = O
= a a .= 5
-5 I I = 3' h 2 3 - f. i Jf $- 3 :. E y 3 5 .~ '$ I : Z E = 6 e r 3E .27 1
- 5' 2 . u=
gn -a= e -e c.g *- g = - .e
- rt.r,
=
n c*Ac,xg . 2.E = 5"b = - p e m,a-=- rg 5 5 r 4= o*:=-:4 3 :, TH a = -u o=*=5wao:2
=
A1
- 8 . a==4 e d c6 - = *6 :
iz=tgu == r=Edi. r!5 =* [ --- 2292 a k . :; 45c r 0.= p '.3 2 s .= = s
- E E 6 F< 23P T ==3
- g=.m
- S-I ~ ; *= * :. =- 6 ::t un =n- N
- . m An .7 - u
--M= r ng -=
2c 5=- { *
= =*_
= r'.M ** -;'
r r.-K .2 c _' Se 4 k- 53 g, -a - g
$ 5 g = c.
s =- r_ .
,3 g. 5 g.* ..=.'.45
=,33 . r.-5, eeg.- . = c s . .-
u - = _ _ _ E = ,: p t z. O e
*- e-ta ;= -2a:E=,
u
==-=g:
gsa=n - ===- i 2a
-3 j f * .g4 'g!a *3sLaF '= T k: - s *- !2. !{3 2.a= 8 ". a2 4 3 A e=n9E, E 4 ms-50== C
'i!
w 3Cm
,3===5- .- 4_ Eg1, =- e a . E 5 : J.4 F" h 1 =- gEx- . C
- S
,3,.- =u'*
. -:e
_ r " . -.1 - =1 ,. i. E = . . 5 L s. A5
=.2 3 N a -@ g ?:-Er - " 3=.g- : r--
- .3" E n *-
O Ekg:M=- E1
- e. r y
= 4-A r, .eg 3~ *e o _ru -u4 - 5 8 =a r 1 s 1 9 .x=...
. S , =, 4 - :r 2- n a< -_
2 _e C
=- T -ag 3 : * =- 5 . * -
y =5 2 n. .<nE. ,, E' = e r
- - , =
g - -e c ~==-T*UCE3
- s. a t
u _6
- , o y==,4f_==;_. -I
.-a2-
- s u!m--2 r ==ix c c.
I - 9 E:= E U. --2 ii - :-
#5 = ll. $ =*
= s.-.
.=_ r=, * -= -o
-n we: ,. - = * .=.. =- m
-E-2:4
- .=*-*= =
- 4 = e
. =-
.e 2_
g44. 6e 2. ' h e -4z ==-2 =G E M
== - -- 32, - -
o - y 3 : 4
$.r 6 r8n - = =4ua -:. 4- c. 9 --- E = sr e M E54.A=-====- =o -
= k =- - r -
g
= 4 m., , ,, u ..t
.my =a
! k 5x g = g .- s g-gs.6 2 :- aEi= .
g48s f 2 .=
. - ^ -..3.
r
*e.
=_,*
- .=. . *- gI
=
8
, -=
'] g
- g. c= . "=.n
=
,r
- 4. e -
*: =.: a 2 _2 = = 4
=- . 5
- n *=
T =- h=- g 2 t, --r t - y = 'n. w ea , -.u-u s7 -u = n _. .= 3 'a,'EE.R=1
!. a =, - j- ,. ;_ 5 h - =-
g=52 3 .= - =l 2. 5 Er- g2 =, n= -o h 4 = P .'mr =94 4 2 .:: 3 2. = 2. - h 3 : qa s a -. a. =. 5 x E g=- m w. . + _he4-- - 1-
.m Q g .h(gg g g
- g g g ggg
_ e - W .e. Ju. # .- e *-ea e t 1
c.
. ,- c. . ...g ..
y n .y; ~.f' g i n 3, x 4 &.
.. K u '
.. q ;jm. e.g4 , e w %,w . . .7 . .
; 'O
/
*+&,c. .
,f
,' &,c F'~e% m q .;* ~. .;;. . Q. ; w' . J --
Y
.Mg hy h . . q.. [ h -(q q ; QMy- h k g ; '-o..me:)..; .9,**~5# h;p; *"f7 w - = e % .-== = w. wit .. _- .
. 2 b 1. ? 1.he;._-
, - 42k3y4
= - . - u u_ .M=.- 41 4 E
. m. F : 2.2yyy,. = ,. 5 g,, s.= - ,- -.
- 1. T
;. e g -
- g -
Ra
.e u
.===n * -
. l
.a .4v.= = 2 u t,- = =. .u I
g
.t.t I 8
= -a.-*k-07a =n1== e e-a .a o u _- 2- i 3
- o.
3g nn- CC=wV,5 =- ,=.- qwg m.g ) o
.}, , =
b2*I y =03 m .~~ ]
--3 =.]E.o-3 _.55.R $
I 3e E 8. n'
= 3,2 w a y-
= 9 _v .,,=. t t .=- .$c a u os u=w ,a,, , I 2
5 o - 5 =. gx e 2 4 :e 4kc-1sa-= -. E*59
-s o u=s= z . _k - -3*
_ 1 g
- ig o - 3 ,. :
~n9mn
=
a E7 e.
.cw r9 n = .: su - 0
- e.=. .,Ms=-o.2 *2
=C~e.s u
-: u a *u 9 i u.
2 2 r.= - = g r- . Zs* o
=
e
- - * ,2 =5 x... .r N R32 -
g =o= .= s .e.3 y-. c:g
,m 223g.- ,xz=- - - o- aw- -
a
= = ' p..
g 6--
;;m-iW e
- 3. 5 ,2.c*s==2 c .= -
.Csk
=
z c5 w 80 4
=3'
=9 .
R m w .3 x
-: Eu-t=m 55 o-kg- sW ,.< *wCo 3o-a is 4 oa t g+ = 4 =
- t ku-.-gx g .= y u = 2 9 -
w s *~- d O 2 % 3 # g'('n6. - " I , .,= . 3 TI 5 2~ 93 18 . -l ~I E Ef 3 x 2 %,N- - g 3 .e y 7~~ 21's ;= ': i E o2*E = z .= a z t .l-o. _. i. =y % =I :~
- 9 .:w5 .= <*;
u j
= .,
=-
I 4 3.=-U 43 :* r : w=.z..u'-y3s.yQc e - 1.s f j o
= . . , .,2 ."! g. = "I 2'
=**
te., 41.d 5 ) % , 3 za h jg o r * .=
.; - - - - -t C*- = 2 u 3
-.=.=
~
E= a ;: 0 ,. . t
-j ^~ M MSN31 380bd 0350dx3 ", ,!$:;'E=~C=k k .E * $ -!y $ I i o 3 2
9 0 1 .i.,g = rror. 3 suis
,C '-
=
4 =14
-u=-
~L -- o - .n..~ n= -
u .. s . L g 1
.' 4. x- r k ? -< We= *auye. a6 a a5=
- : *-s ==,
.a rt. .-
s"=*,s-y =u ;'!.5.e.
- t- 5g,3
- 4
- . 2 > e wz .: M-
= t 2 r - .* *- 4na9 E q=k .= k 3 *;:y -
I4 - I "I 2x-Y
~
s j; C j 3.- y 3 , 77 - - g. j g ' .; g-- lE1
.g3 s
gg k g 9g g ,u f _a .g
==?x .3 -
x u t
.=.8 7a g k. ,.,4 6 n ; t a= .,.e k
= ! r .f=
=, u-wC .. ge
= a ,egec - z.=f,5 - . w g1 2 - [ ,3 g a =- a- : I" -
=-! k=y-!k3u o #, _ f
~ 5 = == = .t. -g ===.9 : .=
te=E75 i-
--t 3 v0=ag.=13 -' 1;-
j!= C=i 5 il=a "C :954= 23-
=u 2 's k -i
-fa < "5 gj
- ! =g .u5 a: u;
-!=3 [IIEd,=
- , so-a.
w
~
t.* e..: m,.. 7 .5 u 3 .1 i>== t Ekok-C
-56 u 1u % .
k s E. -*.a-m.1a*'5 : 5. ;-I F:==
.j E' ,: --si
" - t4 ie =92= = .1 :* 2 -
- i. 7' = n , ,: u 2 G z .'E = xu [ .i'i t ? :e =5 = -
8e x2=. -*- 2 'i, i 3 - 25 k=: o --
=G - ..
[6 a.= j -E ' #5
-v -" usos,e
>= ; = 6 r .' 2'>* ~i E u I u=-
E ,. , - ., - 3t2- s. .e m e,o=w .. s U -
.s. u-u n =, 3 5
, 4. .' 5. --
.J.=.sC.,' -.u-.'
,x-
.n E
a k..t , t.3 .= o 2,uy-C-2..,-=o . =. - = w=
- g ,- .,,- s ,,. :._s 2 =
w
==. . .4 . .=- . .= 7
== 3, .-
ou eu;,95==x
=.rr ,
- s, .t e.= a o = =9 =a c. _ -
-a -
-=;] -
=- 5
]s==s;2Ee-22;:,1 : ec2 y z
=- 5s. 2w=
-8 ;a- J =a .s
.? < s k , =
y2kg-w =- =,== r !. gw U r7=iYgBr -
=8 .o i u -y e -:
, -e C-kp -=!
u i 5 gd 1 E- ' .! T ,?;I;)4 I, c . E= i. y- = o: g.':. O=2t u ! 2.; titt Y;E- o g- t C=2132 a
= ws
- = .2 ; i 4n
,i* . oz
. d"3 -k. E. te ' s-r-s - .! 4 =: .;
= => = s =5.. !.d; .E
's ?= 5. c g :
- ,gr5 =;c < =u c =
- s=- .= 2, k . = >:
e .
.: a. : - -
.r=1, .m = '.=,
a 3u se 375 3 : ..,k..! ,e4s a. ! = k .=-= r g -3 u- - , u
.=a a:
2U4gZj faj=g{pg s =, A, s O 3- jE. .: f =E = j=.-. 's "3 _ .I .E_- l- =5
,3 g ~w ya e I. 0 $O _ $ ,5 u= u==-= j j 5 y ~$
= 5r ,= uw. .' I = e *s { =- ***k#
u .. 8u : 1 =
.- r =. '
'2.- : 3 =,g.
s .a
. =- k ,u ' s==="=5==' =7 -
- $3
=7 5E3 y : =?==,I 's == f $.= I S a
j 5 N, = s ? 11 y ~), :-! 9 j "5 l i i l = ~i n =- t .-d
- : == 1ux=;
= !. e
- =-a- s. er i: z u r,
o . z :-s . = .: :3 u. u-.-=x .=c..,:
- k g o , s== =5 a e. s, :
= 3 : : =, ' ; ' :e =.,==,w.
= ma::
- .=; 3
. . . . . . . . .....o n o mea av i.. , ,u e .eew al ... .l ...g. s.e,.a;m .1 d. ..ig ,ne .eul- f.e _ e.e-d snogan.m. l..r N el s iria inuhe. alu elettrateu r en alw sterngile of l rse se s sse a
ese ao s som su e. , . poolmst asul einnp.muun empeof ril a saluulos saiini leswee 115 gesarm - p p [ f.n lum 4ne ngels amu eric so 17.3 genens 8.n high usnach unmitic. j 's g q - h Ile gerain low n gairant 1.w higli surngth eumacir is geolulah elue i h eaun 8 b-- - y - - . - - -.i, ) l - so the 1.u r slut the sueuscic surt.uc gris baselor with age aml uersis:ih I ~~ " ami. omwipwmir, nunc stuncring trushs as one r?l miins air peulmil. u -...~ - .- - a { !
; ~
I sooo -- IH-- ' ais. [ v i g
.g-WIND 5OR PROBE EOUiPMENT AND NONDESTRUCTIVENESS * '
I l e
, Il. cit nu ilui ihe wieulun pinle seu is a unwirunuiiic ini ! a= fC7 := Co. e is nos cs.u il, u nsc. The gnole Ic.atn a suimm ihuurlurar mi a scrs / l lf' 2 ! - .. - - .A 8
f* unall aec.a m'isti a S/36-in. (M unis) hole in ilw roswicie im the Irpil'e [, _ _. _ ,_ ,' i
- 5; of alw peobe. This d.amage muuki he of listic sonepectue il snaing _ g y . j' ! ^
wne twing saarial out oss the side of a wall ih.as is to In h.uklillnl m on a fumulaaion slab shan is so bc coscent; lumever, ces an esganni [
* / / 4
,m_. __
. . . .g #
? ._ _ _ _ _ _ !.., I [
=
f.uc shc d.emage wemkl Ise imWglish. The gnohes wouhl luse so be /
/. !- 0 '
scuusini asul the smi.ne guichal at ashint voss. l he ecsa mar he u / { ! I sond.irent muulnniutive so the essens shas soineene can he sesacil in i an - / a
-/.I ,l so L Usu amt unusinal memicis uuh as setaining walls necil not he alis- j j r e.enini aber sewing.
i j <>
.. en se e. e. a. ,, s. et ; , i e apo=ro raions teessrae. sai opoasi. , wimi,.r rione Teu rep.j .psic .. 1 he wisul. '
wr 3Hule uI.selsneerset .is sisuIsle* asial m aalisse slic gtasOe of a falaenatory %. 3 M4kws4 Ween nmd mW kyh W H & mms-act ineu. .s.eu. ~llac op.sjnnens a.s well tie.eilc. e saggnl. ain! stenis little s.we serengali el concrees es oboe.ned by efellevene savest.gesors. iFre.n Refs. { . 4 3, 4 3, ,,,g g y.3 nuinten.nue esiogn smaadoeul alcaning of elec lustel of the gun. The , l ssunn has a numhes of imsliin s.alcet (canun ilus pinen .uiselem.sl e ini erwhs sn Ln is ihmbilui uhrilws sonipinsisc uscugdn aan be 1 diuluege m cu. ige of she gnoiresite loom she gma. Iluweier. mearing penhaint wiils sc.eunuble .nomary mitiums etwning to I.nge numbers 1 of s.eles? glawes is suongly a hiuit. The scplairnwns of ele singic- of gnoin.s ger scu."m er l peohr irmpt.nc seu) le nenini an em, ws. - licenner of the f.nge r.nseninhty m she profic tot ersulti, shc i I usrluiness of this appumrh lors i.e determmung the vrlarise qunhos al enm urte ne piner rather shnn in its use na n menres al qrmns.carnwls DETECTION OF INCREASE IN STRENGTH WITH INCREASING AGE pareluteng she 2.% hey comparuiw strengsk of onenrsc. le fus furn dmws: In .insi" an.1 Alalliona** *8 eleas for she s.ure eenuitse mnione esguswil longils of the peobn imicaml with g asuica4ng age ol coeurcie. Tiracloac. the Wimtwo peohe meaune. l WIND 5OR PROSE VERSUS CORE TESTING I E moins eau le seulut hn aenngwr.nive saiulecs. , le lias invis unggesar.I'aslui slic Wieulun piole ersi is seilicieur su ame inseng ami shouhl le eusimleint as ans ahrenasise to ilw laner for ruinuting alw senn lnewire onsgik ni samusene. It is stiac that the j i CORRELAllONS BETWEEN COMPRESSIVE STRENGTH peole seu e an he saninl one in a nutwo of minencs mhercas nues. if - AND PROBE TEST RESULIS loom espowd aires amt il alw? luse in he inant in ascunt.ame maili lle sonel.nisms Icemern emuperwive surngth aiul lnobe MI18 C rh.M. nuns he wulal he let he:" alw. s!.c soic uus luse { seu irmhs aie simwie ins Fig. 3.In Ilic l.arge saciasime in she peulw ; i.e in. :::msgunint to .a erwing lainnann3. causing Imiler akt.n in ; l ~~
' 't . s
. As -
. .r g . ' . f or**** WM J. g. i9.h' -* .'1- - .. - * - m"s - ,
a- _ e' Il ,>: w < N e ??; .'. fS Y n'. s N .' *. h ! A -h . W*'..f h,.j .' : { h}M,,A' g, , . . *! '4g
,, M. .. bM .. [sf.h . , i G*d .. , ' -[ .~1 ..% ' W .-w :
Eh
..,---,..-.m
~
M',
. M ^
h'i'$ I $45'S ., h% ,. N"
.-,.;__ -T-
-- - + . - .
s, .. .. ..i a esos e.nl 6mpaul93 g
>=s a el .r. alt $
sm os s ol s.ep.wl g 4 e.se Amt >=r.=4 e , (. ins >9 3 1 agg no e is ! J anny, ne gang um.s3 lusacs sug=*ags4 (emen gut s ggg) we gg a y Po en2*um asmsutume 3 : esay (.netukte .m eeu s les uit
- uvs s n'.O ** Mr*P M**d uG t il se la, inse g ly!,3 site m est yt a gg a y gg 3 6 3; ing34.e=Hgiset!uk*b
- Ouese utgg a se, t so,1)
'.o e vi u 16 l*e E lluG *tle " "! Vt
- b;
- 9 kE 8 '8 "'"I 8 8'* S8*)
Duee eten % wee s ageef kb is; g au 0 50 648' & iSD **lep ut-y s t; h 6; gh $6 Huus sat,91
- uti B er.t) lb th B O'Jss o bg 4 gig siangua tag i,pj t y s y g,g h g.si e s*J unus in,g s cty a ggy) lh && B la.u s t ". juse & Ig> **tt P Mf'8 R 15 h 85 bl h (mm tus a ;;g3)
&& il k l *l u eC tuee & &ns 68 M*!1b u! gg m y g,g h .timimaue! l saunggegg WW-uu", a ogg n gia)
%b !*J A '48 u
- 'C (" ' & 'k
- hill 'I'P "i y B UC 1 Ut 53 8 (inaeu-eug n Off
- alli eV is 6 Li10 58 l'u' *& *t e'A I *t*P '"t 6 E QC E g[ gg g 4 Est dea 8 92 4 aemen. nuel p$e4 3 sa ni ed et s tep supud gun.as euus u9 seg swe ari or i ^, esse , , , , ,
p ea pe sepeans 6 min m, pau jui n.J... Pe P* *8% 4.ht maa P' alt i. aira.sian, uc2.st3Ne is.esratsmasug g,,,g,,,,,, we = au == n se ** I musutsen P' alii saueweinsoew eqoad go uopopea jo susp! gees puo uoporop peopwoss quoq.urqqm-rg 31gyi I
,m. s.n, w . es soo .. = winwees no.. ., 3 . _ , , , . .
.= .2 s _,
= - c .2 a st 1 -gI_-+cyn= c = -. nia
- o n. s e ,=
= .
- o. o
- ~
2, w-c _-
'4 - - ;
I. .=.,,i,,.=.=c c ;e- 7_3 = a -s
- . =-
t
~ 24 c sa
* }
= , :.- = s '==kuf_s i s. s t s .=
- t. "
4 s .s ' ev e- 9 l- ll
- !=512wi = us-3 "
g{:.*c 2e cc
. .i i I. .
. 7 s '
8 1,, b ,E a-ne
. ;cs w :: =
1:
. - i, r i. i i. .
" e 2.
mv - c s _, .= =. = 9 . as e =s =s= a rr " s, s s . -
= >
x x4 3
; !. . . s. ;. - ; .-g==g -
c 1, s 7 ,1
=
a . 4ti:c :;.-- 2 ,- .: :
% =
5 .2 . o,, =-,, _@=- - E =- N. ; v: b
'N \ j!): .
.;E
; il
- -=-
G t *,* k R = 5 a .!! :c . s :;, g 03: 3 !, Y \ lf )
\ \\
~
k.; bi'o6=== N- I I ~c $ Il )f l* 1
- o g - d g .,.=
a
.3,g.;= = . - 9.
a I s-I ! b I ! ~* I e _ O e - Nx -
. 21 ; .s , .e :s=
i I -. j,k .!M r.s
. .
- s J, . = 2 g -j e.
~
il , .s\ s S. =*2-E*1-s =a =n.g g 4.; _.- . 244 2 ..=r
.- I
== ,9 m ., =
- 1 e. 2 =os - r
. 1 Y = 1 2=u -
e= 2 E* z l s a. gu-,.w . 2 = g l 2 3 =3n-l' a T - y ..=J9 kxs: Q g 3 E .= =., =,: >
.- ~
1 3 ,,, ar l *l 1, 7,, =j - E 3u _5 3's ==c= h, :2 E : O= E
. . -=ge y -
h 'y "I. 3.! h N N h b i b
- g 7 $':s *s-C E
4 a-'s. seisava w-e>= s ao =4 aus aussm nos aio-sa ,.c ! ==2ys.*I: E' s O
- U '7
. m. - . w ,. _ ,- ,,,,, - _,,. y .. ,.. , . , , , , . , -
,.e_ . a ......a.- *. ,,/. g ,;;,,; . .., , ,,,, .
cinessas.o secusmoues 3+
.lcs ss.n=Imil nwnseine mg seauheinen. Lrriang alw tmm; gesi.nl alw l .stimk.s. ..ung a yo ul hcMeng g.g u.ppleet in alw manulaisiner. As l u..w as ,l.r s,. . d.a ....nul a, ..i saw Iww ,,,,, ,,,,,, ,,uus,a, Is,,,,,,, ,,.,,, , ..I,ra r,ai ..,,sh.,..,eab. ,
2 'lew ilure spre suicus m smugenume at alw a::e sjn sif.ril- o, Muse is ilu s.aner as ousherd in linus 2-1.
}
.mng wan.l.es.1 insmg gauitduir. aint estans .hr nudes an tunnels ,
p-r ugu.uc soul, an ese Lslugrams p r wpuse stunuwire ami saLr alw \ .ic al s.debr.nione a mic is shenm n en Fig. 33. n.grilwr miah i ai n .egr. ^llwn luc slure gaoles men ihr s.>p wert.nc 01 ele $1.d. as dw en isirens sunfidnue lumas los ieuln ulu.nl sahws L hhaan.on , d ir.no e. in (l'e2 mm) ap.no ami as Ic.au le see (l'e2 nam) hum slic olges' s hans pd.hdad by incial imeuig. inns f.x sueu trin m.nic miih imic- ; 11.ms of slw elure pulws f ails ses ge<>gnis givernate she slals. ernunt i unew, ge. net, s hces, ami esapuiL aggte%*in aie showie in Fig 3 9. j n asal fuc .emalws. Alake senr aliar as Ic.ns almt salut pulw scudas 8
< air .n 4.l.d,1c. Alcaune she espmril puhe lengsle. imng a ungle poise g souple e asal etw sk pah gage. Averai;c elec eluer scushs. l ,
, ; 3. Ittprae alw almne pauseduse lem all sna sgwaiment EVALUATION OF THE WIND 50R PROSE TEST 4 8 Ploe alw espnril peul e length su emhes os smilemricis ag sms alw son.pewise mengde in poinuls lwr vpute imh as in kilo. I a g'd** In *Pu'c tr'nisucks as a grapla. lie a snese m line 1.v the UAuTATIONS OF WINDSOR PROSE EQUIPMENT '
; nwilmat of Icase wpuses %mweimn 9's prurns confalesur limiW for g 3,,. wi lw, pohe c p ipmens has the potential of pmid. , j iminielual erwhs nu) alw aw ilsawis ois the graph.1 fww lemia,' he- ing .e guid nu .ans of shetkisig epulus of coeurese in sisu ims its Innisa-9 sucen alwns mill elew reise si.e imental within mhieli the prolsabilisi sioin umu tw recogisised. Canine of these ase dissuned below.
l '
} of a ens rnuti fallmg is 95 gwrtens. l ;
I j 5. ll compewise warngels of neu sthmters is so Iw relaird . i so alw prolse gewisanion scudas oss si n 12-ias. (152 x 305-mm) estimicis. VARIATIONS IN PROSE 1EST RESULTS 'l L
, { ilure to Ine ens <}limicas ase ease asul one gnolac oedy is fucil iis c.scl' The liiniscti pbladical data ley C.agseos" .%sni.** asul alallio- ;
g q I sia an imlisate ilus the vasiasion in the.psohe test innh> is lasge as l ; s u a b
?
(,- ;s-( g
.m s:.
6 ^ '
@ @.m !
1...
.. , ,. g . @. . 4 g
j, ,' Lt n-
\~. .
\ t'
., SL g
1j&'g}j' s_. * ' Y: , e . lM & -
. g gg. g g m
...._._.s.._.m.s_~~.r._..-.....,..,
. . s. . . . . i . . .. . d.- l
..I,
.....~... 1 i 4
t 4
, l -
-- .- , --..as-- a .a- a w , -, . w- _ . - - - -
= h
= ~$ E "= L' .$ 3 W k I u E
C k= =E'I ; i. 3 s,a5 ' .2 3 ' 7-as~ lo 0 .=
- N -r 5
W Q Q 1' [ ~ M M R W Y =5yyE " f, .' -. . 3.4o- *=- j ez= .= .! rzt* , , s
. i "E O j. 5 2 .=
- - - WZ=e ,,ugw I,
% % l = .- k.3 y W W == es-. = .,,
A
- g. l &, 5
'3 i
3 s =
* .:a
- E-2 = 3- IC 3-C
$3
.= $ es s .=.
,'"=4 s , -E W .'E.
'i{2 s- f g "d3 m. 4 k]$ j a' any $ {-h k b ) [N ,,,, 'ei'[b
. -- 1 *
{k f.! b - 4 i ~, W s y s ? .! j; ; ~8 5l3g 1 l "
= E5 I *'*Ig l
'IN.Wvi 4
C 3.Ijl$
=5 tB5 ,, $!..=k f "l .t-
- a}
__ -- 5
?.T3' 7' l
B 3 -E- g-Xn.d.5' 5 g 3.2 d, .! i==-! 6 -' e
'W ,
,yk- = g , .,,;a - -;
...,- - s==, -
t"- gl-a ;z.]
, = 3.:
3
- - 9 Mz -. 'M y =. E
= * . = = , w;-! 2 : ,.=f.=.
_I_ 2 .4 s .s a
=
i e -u- "
" "*-J.? .;
e a"W3
..! 2.2 - -] aj
=,- NEi :== ,s 5=a,
- 3. E
,=s u-t .E J-g r g=E 0_-0;-c-
-=
5 t g :k C 3 8- 7 ! g ;if 7 c: - D ~
,==
@- s. i 2 -2L-Q 3 -3 = = EC2 O 27 .; 2 5 3 - ;l E { ! 7EE: .
i=;.j:i.-.E 7
- - mIt -
r
- - : J..:2 ki 25 -Y 2.'s
's. 5 5 :: '* a t
I l - . ,=
= e.n, , . = . ,=6_..t rs ~ - = ' = x- , =e
-4 . . *
.,s.e .~:. . .g: ..., .;, -l v-r -
- o. - .s ,
i
,.c q. "v. :; - , . .
n s ,= n.=t. = .=- e=s - -
.a 1 =
,4 . , ,
~ ,,
* ..s. . ; .,.,-
3 .n* .4
' ~ ^ =~ :
- u- ik=o .= .=; -l -y- ci l}
f --d?f.. t?.. .Q i:11. ?. 4-
... l 1 3, -
E 3 g E ~3 !y k y.:,'y-I'.: ' ' a ht D
. $ e* ,
h *= *;*5 4
- = ;q o I -E S '. e E e sc y n . G . ~s t E'
- = c .E .5. -:": ,c .y, n. y
~= ~ '* 3-
' k. .v-'. .. "/..',q, 'l ~.
i e 4
*i 8 2.5 E W ~2 5 l j 5 :g ;y g 3 y-
,3 r-
..3 .4,
.)l j ="
.:3 9*,
=,c
- ; e, o j .= .= k S[
- y. ; :u: :k i l g;* , -; -u4
= ee-6
[I ,]. 'y' A ]7, 2s= 2. 3 ,,. 2 _j.:=. 2 C l. .=j .gF i 8-- J, sp
,e "t2*kkt3
, e* .')
- G V ;g; -
m i = ' . ,.
- e. O ,, 5
", : 5 "E >O k z :~.
E is a: kw - g ,- =3 .E g5=n= . T.i -E 1. s 3
- 'I J< lC.
5
?
.j 4
= est W = =g--{= = =t
$ =k k3 t f, = ; ' 2 J g ei I.-
.$b3l i
I
, *: W i f II5 }cm33w 3 Sj=;'i 35m67 If 2 ; 4'i
- P .a
$3.{
}2 a-'s C' tS=5 s- j l}j g
*)
"f. y; eh .% .P-atr-vi2t k" v = j; t g ao = = 7 o 9 =2 :, .=
. [L g a g30= : O :; ! 1.s
!. ,. 4 3 % a b 6 m r =-;E" ir=2 *ts
- I I. l d 3-0z .:f !Y b .I-- = k !
;: $hh 2. ,j k f
<i ;.1 l..
* . :=
e .5 = 3 = .
=3k--6
- = ..: =
5 - i st 7
. . .g' k -
- e. - 3 2
,A
= x -
t e
~3
-p2.an=.$3 .,
(
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