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The Applicants state that these additional loads did not exceed applicable allowables, but what are they using as an allowable stress?
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
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. Cygna agrees with me regarding this, as stated in their August 10, 1984 letter to TUGC0 f5/, where they state, in part:
: 3. Cygna agrees with me regarding this, as stated in their {{letter dated|date=August 10, 1984|text=August 10, 1984 letter}} to TUGC0 f5/, where they state, in part:
                 "Sased on a review of that document (Applicants' Motion for Summary Disposition on axial restralnts), Cygna does not agree with the interpretation that the rotational constraint provided by the double trunnion trapeze supports constitutes a condition of restraint of free end displacement. And, therefore, an increase in the allowable stress for these supports is not appropriate."
                 "Sased on a review of that document (Applicants' Motion for Summary Disposition on axial restralnts), Cygna does not agree with the interpretation that the rotational constraint provided by the double trunnion trapeze 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 is based upon a false premise of increasing the allowable.
Therefore, Applicants' statement that the additional loads did not exceed the allowables is undocumented and is based upon a false premise of increasing the allowable.

Latest revision as of 14:38, 24 September 2022

Affidavit of M Walsh Providing Partial Answer to Applicant Statement of Matl Facts as to Which No Genuine Issue Exists Re Allegation Concerning Consideration of Force Distribution in Axial Restraints
ML20096B941
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 08/27/1984
From: Mary Walsh
Citizens Association for Sound Energy
To:
Shared Package
ML20096B875 List:
References
OL, NUDOCS 8409040429
Download: ML20096B941 (41)


Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00

~ BEFORE THE ATOMIC SAFETY AND WLICENSING BOARdIG In the Matter of l '84 gp q

~ TEXAS UTILITIES GENERATING l Docket _Nos. 50-445 b COMPANY, et al. l and :50-446-d)(_

l (Comanche Peak Steam Electric Station i Station, Units 1 and 2) {

CASE'S PARTIAL ANSWER TO APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH-THERE IS NO GENUINE ISSUE REGARDING ALLEGATIONS CONCERNING CONSIDERATION OF FORCE DISTRIBUTION IN AXIAL RESTRAINTS in the form of AFFIDAVIT OF CASE WITNESS MARK WALSH

1. Applicants state:

" Applicants' design approach for modelling trapeze type s'apports with trunnions is to model the support as a single supporr aering in time axial direction. (Affidavit at 3.)"

I agree with Applicants' statement, although their philosophy is wrong and this is not what they told the NRC Special Inspection Team (SIT), as will be discussed in answer 2 following.

2. Applicants state:

" Applicants' modelling technique is reasonable. The modelling technique urged by CASE would be very conservative and not necessarily a more realistic modelling technique. (Affidavit at 3-4.)"

I disagree with Applicants' statements. The Applicants' present

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. 1.- J 1modelling technique does not take into account.the rotational restraint providedlby these supports that are welded to the. pipe, which CASE has argued should be considered and which the Applicants' told the SIT they were going to do.- According to-the SIT (as discussed on page XVII - 6 of CASE's Proposed Findings /1/):

"The Special Inspection Team concluded that the rotational stiffness ~ associated with these designs should have been included

in.the piping stress analysis. Subsequent-discussions with the-
Applicant indicated that this. rotational restraint had also been identified during the Appi,1 cant's normal design review and . that the pipe stress analysis was being modified to consider this rotational restraint. The Special Inspection Team reviewed the proposed method of analysis (' Minutes of discussion at the Meeting

'between G&H and NPSI on March 17, 1982') and concluded.that-the method of modeling the rotational restraint and the attendant loads on the scubbers was acceptable. Since the Applicant is including this rotational restraint in the pipe stress analysis, the Special Inspection Team found the concern on moment restrsints introduced in the piping systen to be resolved." (Emphases added.)

2 Since the Applicants informed the SIT that they were_ going to go back and take the rotational restraint into account in the pipe stress analysis, the SIT closed this item -- based on the fact that Applicants already knew about the problem and the Applicants' representation that-they were going to do it.

i In addition,- the Applicants told this Board as part of their Plan (Item 15) /2/ that they would:

I ff1/ This. problem was addressed in detail-in Section XVII of CASE's 8/22/83 Proposed Findings of Fact and Conclusions of Law (Walsh/Doyle l Allegations).

f , 22/ See . Applicants' Plan to Respond to Memorandum and Order (Quality

-Assurance for Design), February 3, 1984. See also Footnote 1, page 2, .

of the Motion being answered here, Applicants' 7/9/84 Motion for Summary Disposition Regarding 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 of axial restraints. This evidence will be generated through the performance'of analyses."

However, in their Affidavit-(at pages 3 and'4), Applicants are now

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"saying,that they don't have to account'for the torsional resistance of axial restraints:

". . . the rotations are very small and accommodated by the play in the two legs of the support. Moreover, when seismic analyses are performed using the response spectrum method, as is the case a*. CPS 2S, the resulting support loads are not dependent on the relative phase between-the response motions, 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, Applicants believe that modelling the restraints in questior, as purely axi_al_ restraints is adequate."

(Emphases added.)

What the Applicants have stated in their Affidavit is contrary to I'

t' what they had told the NRC SIT and this Licensing Board through their C

"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 7/3/84 Bethesda meeting between 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 f- this entire transcript portion). Mr. Tereo of the NRC Staff discussed the Staff's' concerns in this regard.and mentioned NUREG/CR-2175,

- especially with regard to unequal load distribution (Tr. page 27). He 0

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further indicated that as a. result of the testing performed (reported in NUREG/CR-2175), the NRC: Staff l revised its Standard Review Plan, Section 393,' to. address 1this issue; heffurther stated (Tr. page 28)

, that lthe July.1981 Standard Review Plan states:

"The snubber'end fitting clearance and lost action must-be.

minimized and should be considerea 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 8/25/84, so I have only'quickly scanned portions of-it). As indicated in Attachment'A hereto (applicable portions o5.NUREG/CR-2175), it.is stated (page 15 of NUREG) that:

". . .La linear analysis may be made provided the total clearance Lis less than .0511nch, and the lead and stresses are multipliled by the appropriate load factors. Snubber reaction loads and stresses shall to increased by 100% for clearances greater than .0 but less than .02 inch. Snubber reaction loads and stresses'shall be incressed by a factor of 4 for clearances greater or equal to

.02 inch but less thsn .05 inches. Detailed nonlinear analvsis is ~ required for systems with .05 Irch or greater clearance."

(Emphases addei.)

For the Board's information, 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 has already submitted (on 8/13/84) a response to the

~ Applicants' Motion for Summary Disposition Regarding the Effects of 4

-Gaps on Structural Behavior Under Seismic Loading Conditions. 'In

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response to the Applicants' statement that " Identifying the effects of i-3 l

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. gaps by comparison of the results of nonlinear time history (with gaps) and response spectrum (without gaps) analyses is difficult," I J suggested using a friction type connection (page 24 of Walsh 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 evaluated the significance of the effects CASE alleges should be considered by reanalyzing several pipir.g stress problems utilizing the modelling assumptions CASE would have Applicants employ.

These analyses demonstrated that Applicants' aasumption 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, assuming none of the snubbers or struts exceeds its allowables and assuming that Applicants have done their analyses correctly (assumptions with which I do not agree). When a snubber or strut exceeds its capacity, an additional moment 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.

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4. ~ Applicants state:

" Applicants' analyses. demonstrated that' changes in loads on the-supports on the reanalyzed stress problems occur only with respect to

- the trapeze supports . themselves. This effect is expected 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' first sentence, with the same qualifications as discussed in answer 3 preceding.

Regarding Applicants' second sentence, the Applicants state r

"which had not been previously analyzed." I thought these supports were as they were originally designed, and not containing any additional moments. If there wete a problem, the Applicants are committed to resolving that problem in a prompt manner. The Applicants

. Informed the SIT that they were roing to cake che rotational restraint into seroent as part of their as-built stress analysis /]/.

2 By reviewing Table 3 atta bed to Applicants' Af fidavit, one can immediately see that, when the rotational constraint analysis is used,

he load can almost double. This analysis had not been considered (to l the best of my understanding) prior to Applicants' current Motion for Summary Disposition. Gary Krishnan testified (incorrectly) that I was j told'in the past that it was not my responsibility to address the issue of welding of stanchions to pipes by NPSI, ITT Grinnell and PSE. Mr.

l Krishnan told me that they did not intend to include consideration of the welded stanchions /,4/.

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 of CASE's Proposed

' Findings.-

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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. Cygna agrees with me regarding this, as stated in their August 10, 1984 letter to TUGC0 f5/, where they state, in part:

"Sased on a review of that document (Applicants' Motion for Summary Disposition on axial restralnts), Cygna does not agree with the interpretation that the rotational constraint provided by the double trunnion trapeze 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 is based upon a false premise of increasing the allowable.

5. Applicants state:

" Applicants evaluated every Unit 1 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.)"

f5/ See CASE Attachment B, 8/10/84 letter from N. H. Williams, Project.

Manager, Cygna Energy Services, to J. George, Project Manager, TUGCO.

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i See answer 4 above. In addition, on August 22, the Applicants provided to CASE on discovery (requested 8/(/84 /6/) one pipe support drawing and partial 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 loa'd . 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 exieting 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 shown 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 new load using Applicants' figures should be then, 18657.21 times 1.459 - 27221. lbs. (rounded off because 1 don't think including the 1/100 of a lb. will offset the 27,000 lbs. already calculated). But

/6/ See Applicants' 8/22/84 letter to CASE from William A. IIorin, Counsel for Applicants, page 1, item 3.

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apparently the Applicants have a new way of figuring their shear loads.

'They use a new method called " redistribution" (see fifth column of table). Not considering this " redistribution," the correct shear load would be 2.45 times 18657.21 = 45710. lbs. This is over three times greater than what the Applicants arrived at.

The insert allowable (shown at the bottom 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 1

Attachment C). It is apparent that the correct tensile load bv itself will exceed the allowable.

Tha Applican:s have also listed the allowable tensile and ahear capacities of the A193 high strengtt bolt in the attachment as 90 kips in tension and 42.4 kips in shear. The Applicants have shown in their-1 PSE Guidelines (CASE Exhibit 724) the sllowable tensile capacity for an A193 bolt as 66 kips (working load), and in shear, the working load is 34.5 kips.

Regulatory Guide 1.124 (CASE Exhibit 743, admitted 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.I.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 permitted by NF-3231.1, xvii-2110(a), and F-1370(a) of Section III are not directly applicable to allowable shear stresses and allowable stresses for bolts and bolted connections."

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6. . Applicants state:

"With respect to lug-type restraints, it is neither necessary nor reasonable to expect that the lugs can be installed in a perfect circumferential plane with zero tolerance. The lugs have been installed within. reasonable limits. ( Af fidavit at 10-11. )" -

This is where the Applicants are wrong -- again. The procedure in question' requires 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 may be academically correct" /7/.

As the Applicants went out in the field and verified, perfection in construction is not achievable. Eut the analysis which Applicants had chosen to perform reouired 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 Findings, page XII - 6, third full paragraph. It appears that the lugs were installed without any OC procedures as to the acceptable tolerance (gap) between the lug and the supporting surface, and therefore any size of gap could exist in the field.

/7/ See CASE's Proposed Findings, bottom of page XII - 5, continued on XII

. - 6).

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_- c 7. . LApplicants-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, fDue to construction, there -

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may be a large gap 1(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 b'een included in the ASPE code, and therefore

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they don't have any more room to play with the numbers.

In 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 is 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. (Affidavit 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 statements. f p

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I Further, as has happened before in Applicants' Statements of Material Facts As To Which There Is No Genuine Issue' f8/, whoever prepared the Statements of Material Facts has (whether deliberately or inadvertently) altered'the meaning of the sworn Affidavits of Applicants' witnesses. In this instance, words have been added which are not contained in Applicants' Affidavit (which is referenced as the l-source of the Statements of Material Facts). In this instance, the Statement of Material Facts states:

"However, both frame deflection and rotation of the oipe 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 Af fidavit. This is very misleading, because it means that not only CASE, but the Board cannot depend upon 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 Af fidavit. Further, rotation of the pipe could even tend to open gaps and transfer the load back to the outboard lug; this is not discussed in the Affidavit.

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]8/ See discussion at page 8 of CASE's 8/13/84 Answer to Applicants' Statement of Material Facts As to Which There Is No Genuine Issue Regarding CASE Allegations Regarding Section Property Values.

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' Also (as CASE has previously demonstrated -- see page XII - 7 of DCASE'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 is 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 e 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 or 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:

1 "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 frame. 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.)"

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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 cons' i der the rotation of the pipe. The rotation of the pipe would increase all loads and stresses which the Applicants have refere7ced.

The second item is that the Applicants are now relying on a plastic analysis, 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 KVII, 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 ure repetitive.

11. Applicants state:

1 "To asses. 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)."

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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 b2 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.

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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-C52R -- 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 Regulatory Guide 1.124, Revision 1, January 1978,

" Service Limits and Loading Combinations For Class 1 Linear-Type Component Supports" -- see page 9, answer 5 16

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The preceding CASE's, Aniver to Applicants

Statement of Material' Facts  ;

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As To Which There Is No'Canoine Issue was. prepared under the personal

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, direction of the undersigned, CASE WitnessJ. ark Walsh.'

I can be contacted brough' CASE President, Mrs J y uanita Elli!, 1426 S. Polk, Dallas, Texas  !

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, 75224, 214/946-9445. .;m ' (

! .-e My qualifications and back'iround are already a part of the record in i

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these proceedings'. _(S$e C'ASE Exhibit 841, Revision to Resume of Mark Walsh,

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, accepted into evidence at Tr. 7278( see also Board's 12/28'/83 Memorandum and t-l-

L Order (Quality Assurance for $estirn), padas 14-16.)

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I have read ihe statements 'thereinira nd they are true and correct to I

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( the best of my knowledge and bliief. I do not consider that Applicants

'~ s 'l' have, in their Motion,for. Summary Disposition, adequately responded to the

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issues raised by, CASE Witness Jack Doyle and me; however, I have attempted to comply with the Licensing, Board's directive to answer only the specific

.1, statements made by Appliesnes.< ' -

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, ', - (Signed) Mark Walsh

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STATE DF TEXAS-l ]'

On this, the '2 7 day of,. p u ds2_

, 1984, personally appeared)is'ck Walsh, knoito :o tas to-be'thejperson whose name is subscribed to the' foregoing instrument, :and acknowledged to me that he executed the l ~ samefotfchepurposest'ikreinexpedssed.

A7 Subscribed and.swotn 'befdre me on the

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day of CW /d'4W C

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. _ . Votary Public in and 'for the

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My Commission Expires
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- ATTACFE.NT A -

NUREG/CR 2175 ETEC-TDRM16 ,

! e I Snubber Sensitivity Study 1

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Menvecme C. e:c. w two Date Pubishest: JWy 1Mt P W by A.T.Onesso Enwgy Tectecn o gy % Camer ,

P. O. Ocu 1489 -

j Canoge Pat, CA 9124 ,

Prepared for i

DMelon of Engineedng:. ..

6 Office of Nucteer Reectoc Reputati3n -

j U.S. Nudeer Regulato4- ,, -

- Washington. D.C. M pommission ~-

NRC FIN 830M I

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[ t ' r'. t It' Snutbar Sensitivity Study Final Deport lanac oat ? ttt f, -s ,

Scubber Sensitivity Study .

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v sta'tw!v ce **:t t=

i Develop infoe14 tion Atch will provide tr+ basis for structural analy-sis and design rules for systm and corvenents iAlch ut111re snubbers

^ as sumerts. Desults will be used to es%Jrt that dynamic response

' s. characteristics of snubber sumorted systems and corponents will be bounded within acceptable Ilmits, aattaaC?-

Snubbers a rt ut ed = l del v t he ak a "ha s e industry as seltmic res t ra i n t s.

%f 07 Ena> .rC - '

. a ra , rt haracterize hydraulic and I l *echanical snubbers wMeh s tent ficantly affect snuboer dynamic re-spoMe; 2) 6eterwine the response sensitivity to variations of these pa rame ters. Based upon tha 'results of the foregoing, siselified desir and analysis procedures are proposed, to maintain system response.,with-in' Acceptable limits.

Ge rm . .* nf e' ieaare ' evi te the effects o j -

.<h4' s.'35;'I art incittded in this report, i

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) Nnd 6dicted with sufficient accuracy in most

[  ! cases, provided all response parareters are bounded within the limits

! described in 2.2.2. Howewr n

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d Snubber reaction loads and stresses shall be increased by 1001 for clearance t

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[I Deta r clearances non incar ana ter or is is required for systems 02 inch but lesi EMGUT recner.--

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j 6 I 2.2.3.4 The guidelines for multiple sntAber usage are based on a single test pregram described in Reference 1.

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load sharing of mittple snubber supports (within 10% of the total load)

{ can be espet ted for hydraulle snubbers Wn end fitting clearance differentials l

l are less than .01 frkNs.and the activation level and release rate are between I

u room ,s u , arve.n

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' 1 me, rTrr.mo.on.16 new, pace A4 or onTe 11 7A.p_1 mev.oare The activation level of a eechanical snuther which is equal to its release rate and defined in terms of its accelerattoa shall not exceed

.029 Application of the mechanical snubber shall be limited to environ-l sents where low frequency loadings (<3 Hz) are not anticipated.

B.2.1.3.2 Release Kate The release rate is defined as the rate of snubber antal movement under load after the snubber is activated. The release rate of the mechanical l snubber is the same value as its activation level and independent of load.

The release rate of the hydraulic snubber is independent of its activation level and is proportional to the appiled load.

l The release rete of a hydraulic snubber is commonly defined in terns

( j of tes t'leed rgte and rated load capacity. The bleed rate is defined as the release rate at the snubber rated Icad. The bleed' rate of the hydraulic

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snubber used for component and piping systee:S shall not exceed ig, whers, Ig

  • RtoifD t010

.50 I (UFPMT W) tach / minute l&. '

If the snubber is used to restrain piping, the component weight represents the equivalent 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.

B.2.1. 3. 3 ,Clearanc:

The response of a pt.P ig systee or crroonent sur ..-' d with 59u8. ars is highly dependent on the clearances located at the sus . ets. Th s is

especially true of tapact loads. f ralustion of clearee(< '. a snects'c

! support location' shall be based o, scubser free p'ay, end " tting clearances, pipe clasp tolersnces, and other clearances not indicated. The support clearance is thh.'umatico of individual gaps entsting betwen the snubber backup support strutture and the center of gravtty (or geomtry) ef the component being supported. The total gap shall not esceed .05 inch.

Potas 10b&T Stv &te f

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' tet cavoen a snee: s#te 1000 sa- Pae:m a w".55N 4'? F " . '

ATTACIIICT B _

- August 10, I984 84042.014 -

Mr. J. George Project Manager Texas Utilities Generating Company.

Highway FM 201 Glen Rose, Texas . 76043

Subject:

Force Distribution in Axial Restraints . Phase 3 Open Item Comanche Peak Steam Electric Station independents Assessment Program - Phase 3 Texas Utilities Generating Company Job No. 84042

Reference:

Motion for Summary Disposition Regarding Allegations Concerning Considero-

. tion of Force Distribution in Axial Restraints, July a,1984

Dear Mr. George:

During the Phase 3 pipe support review Cygno raised a question concerning the appropriate loading to be used in sizing standard components (struts and snubbers) which are used in pairs to form oxial restraints. The concern was not with the pipe stress analysis modeling techniques for this type of support, but rather with the appropriateness of sizing the struts or snubbers assuming a 50% - 50% food split. TUCCO responded by referring Cygno to the above referenced Motion for Summary Disposition.

Based on a review of that document, Cygno does not agree with the interpretation that the rotational constraint provided by the double trunnion tropeze supports constitutes a condition of restraint of free end displacement. And, therefore, on increase in the

=ollowable stress for these supports is not cppropriate. Justification for the 50 6 iood split must be provided on on appropriate basis. One such basis would be to demonstrate that the support system provided sufficient ductility (deformation) to insure that the proper redistribution of forces occurs prior to achieving ultimate load Cygna understands that Dr. lotti has performed some studies on a pipe stress problem to determine whether the pipe axial and rotational displacements are coincident in time.

Although we have not reviewed.the results, Dr. lotti believes the correlation will be low.

However, it may be dif ficult to justify the uncoupled nature of these displacements on o

. generic basis.

While Cygno has noted that TUCCO has chosen a 50% - 50% load split.for the design of the supports,-the some is not true of the welded ottochment local stress evolvation. In all but one of the 16 double trunnion oxial restraints reveiwed during all four phases of the Independent Assessment Program,- the full lood (100%) was assumed for each trunnion i

San Francisco Boston Cn.cago acmans

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- Mr. J. George August 10,1984 Page 2 design. Although we think o check of all double trunnions should be made to ensure on cppropriate load split, it appears this will not be o problem. Given this disagreement on the support design, however, Cygno believes that TUGCO must either evolucte the effects on the basis of support ductility or review the supports on a more specific bcsis without the increased allowable before Cygno con close this item for. the purposes of the Phase 3 reviews.

If you prefer to have further technical discussions on this matter please notify me of this fact.

Very truly yours, e .

N. H. Williams Project Manager cc: Mr. S. Burwell (USNRC)

Mr. S. Treby (USNRC)

Mrs. J. Ellis (CASE)

Mr. D. Wade (TUCCO)

Mr. G. Grace (TUCCO/EBASCO)

Mr. D. Pigott (OHS)

Mr. R. Ballard (G&H)

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ATTACHMENT 2

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NOTES: [ ~,_. _.

4. FOH MATERI SEE NOTES ON AL.

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? AtL BOLTS FOR RICHMOND SCREW ANCHORS SHAL L DE SA - 19 3. G4 07 1HREADED RODS WITH SA-IS4,6H 4 OR F HUTS AND A32$ HAHDt NL D WASittitS.

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_._l22 WASWR WILL BE USE D F OR BOLTS USING ELONGATED HOLES BEVELLED t. WASHER .. _

IS FURTHER DESCRIBED AS FOLLOWS. __

A. THE MATERIAL SHALL BE ASTM AS88, GH. A. ~ ~ ~

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EL THE HOLE IN 1K BEVELLED it WASHiiR SHALL BE A

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C. lHE nelatiMUM lHlCKNESS SHALL BE 3/B"

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Q Tite SURTACE OF THE BEVELLED *"",* ,.

t. WASHER IN CONTACT WITH THE NUT SHALL rw U A nni aim . A . egit 7 .,,- -

NOT TK BOLTHAVE SLOPE OF MORE THAN 120 WITH RESPECT TO A PLANE NORMAL TO AXIS ., ./s t ,c gr v re. n g ett.c m >t E. THE BEVELLED t. WASHER SHALL BE SQUAftE OR RECTANGULAR AS REQulRED. THE SIZE OF TE R. WASHER SH.8LL BE A MINIMUM OF 2 BOLT OtAMETERS IN EACH DIRECTION OR SHALL EXTEND t/2" FARTHER THAN ANY EDGE OF TE [LANGATED HOLE, WHICHEVER IS THE GREATER.

, ASME CODE iDifsOpr

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COMANCHE PEAK S.E.S.

o '! b Agent For rains code cm er .

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ENGWEERING Gul0ELNE TITLE ' COVER SHEET 3 3-T-72.i lOF 1 FOR APPROVEDs SECTION VI GUIDELINE RICHMONO IllSERTS & AflCHOR BOLTS STRESS ALLOWABLES REVISIONS 4

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I. INSTRUCTIONS FOR FILING GUIDELINE PAGES Remove,Section VI Rev. 2 and replace with Section VI Rev. 3. -

Place this cover sheet in front of Section VI flev. 3.

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' SECTION VI: RICHMOND INSERTS AND ANCHOR BOLTS STRESS ALLOWABLES 1.0 REFEREt!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 . RICHMOND INSERTS

~

ALLOWABLE SINGLE ACTING LOADS

! Load 1" lis" Direction Insert Insert Tension 10.1 KIPS 25.0 KIPS Shear 9.5 KIPS 25.0 KIPS INTERACTION REQUIREMENTS

[Tl4/3 , ,[y\4/3 e g

1 (7t), c7)

Qv Where: T = Apolied Tension V = Applied Shear Ft= Allowable Tension Fy = Allowable Shear 3.1 ANCHOR BOLTS 3.1.1 GROUTED-IN ANCHOR BOLTS The following appites to a single 11" 3 9 - A193 bolts installed in accordance with reference "B".

ALLOWABLE TENSILE CAPACITY Ultimate load condition - 105 KIPS ,

Working load condition - 66 KIPS ALLOWABLE SHEAR CAPACITY Ultimate load condition - 69 KIPS

e. Working load condition - 34.5 KIPS

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- CASE EXHIBIT 743 Revision 1

. [g ,,g]o U.S. NUCLEAR REGULATORY COMMISSION January 1978 QFg) REGULATORYGUIDE

%.m. OFFICE OF STANDARDS DEVELOPMENT REGULATORY GUIDE 1.124

. SERVICE LIMITS AND LOADING COMBINATIONS FOR CLASS 1 UNEAR-TYPE COMPONENT SUPPORTS A. INTRODUCTION with the specified seismic event, thus helping to General Design Critenon 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 and its tion and Utilization Facilities." requires that the de, supported components.

.ign bases for structures, systems, and components in order to provide uniform requirements for con. t important to safety reflect appropriate combinations struction, the component supports should, as a I 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 the upportnl The failure of members designed to support safety- components. This guide delineates leveis of ervite related components could jeopardize the ability of the limits and loading combinations, in additton to 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 of See.

l limits and appropriate combinations of loadings as, tion III. 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* I linear-type component supports: linear clastic anal.

tion NF of Section 111 of the American Society of ysis, load rating, experimental stress analysis, and Mechanical Engineers (ASME) Boiler and Pressure limit analysis. For each method, tne ASME Code de.

Vessel Code. This guide applies to light water cooled I near'es allowable stress or loading limits for vanous l reactors. The Advisory Committee on Reactor Code levels of service limits as defined by NF.3 t l3 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 appropriate plant conditions. Since the Code does l 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 . .

the loadings associated with normal and upset plant mp nent supports considered in th.is guide are conditions under the stress of specified seistric I cated within Sci mic Category I structures and are events, thereby pernitting system compone its to therefore protected against loadings from natural function Properly. Rey also prevent excessive com. Phenomens or. man.made hazards other than the spec.

ponent movement during the loadings associated with ified seismic events. Thus only the specified seismic emergency and faulted plant conditions combined events need to be considered in combination with the loadings associated with plant conditions to develop t.ines indicans substantna changa from previous issue. appropriate loading combinations. Loadings caused usNRC REGULATORY OU DES w .a.

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. s by natural phenomena ch:r than siismic events, strisses sh:uld be calculated with the vales (f E and when they exist, should be considered on a case.by- S,'of the component support material at temperature. .

case basis. Allowable service limits for bolted connections are g denved from tensile and shear stress limits and their

1. Design by Llaner Elastie Analysia nonlinear interaction; they also change with the size of the bolt. For this reason, the increases permitted
a. S. .at Temperature. When the linear elastje g,y 37,;;3. i, XVil-21:0(a), and F-lyl(Ma) of Sec.

analysis method is used to design Class I linear type tion III are not directly applicable to allowable shear 9 component supports, material propenies are given by stresses and allowable stresses for bolts and bolted Tables I-2.1,1-2.2, I-13.1, and I-13.3 in 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 stresses 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 4

the level A service limits because of the potential for l I

temperatures but only room temperature values for non.ducule behavior.

the ultimate tensile strength S.. At room temperature, S

' S, varies from 50% to 8781, of S. for component sup. The range of primary plus secondary stresses port raaterials, should be limited to 2S, but not more than S. to en-sure shakedown. For many allowable stresses above Levels of service limits derived from either mate" ,

the value of 0.6Sr. the increase permitted by NF-

nal property alone may not be sufficient to provide a 3231.lf at will be above the value of 2S, and will i consistent safety margin. This is recognized by Sec. thus violate the normal shakedown range. A I 3

- tion 111, since XVil-2211(a) of Section !!! 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 method, F-1370(a) room temperature and to provide a safe design mar- of Section !!! permits increase of tension limits for 1 gin, an interim method is given in this guide to obtain the Code level D service limits by a variable factor

values of S. at temperature. that is the smaller value of 1.2SrFe or 0.7SsF . De-i Pending on whether the section considered is a net While XVil-2211(a) specifies allowable tensile section at pinholes in eyebars. pin. connected plates, i

stress in terms of both S, and S., the rest of X\,!!- or built up structural members. F may assume the

2000 specifies other allowable service limits in sprms smaller value of 0.45S, or 0.375S. (as recommended
of 5, 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. 3,naller value of 0.65, or 0.55. (for a net section real 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, j

limits. which does not account for local stress and is not

b. Allowable Increase of Service Limits. While consistent with NF-3231.1 and XVi!-2110(a) of Sec-NF.3231.lfa), XVil-2110(a), and F4370(a) of Sec. tion III. A procedure to correct this factor is provided

! in this guide.

i tion ill all permit the increase of allowable stresses

! under various loading conditions. XVll-2110lb e lim.

t. its the increase so that two. thirds of the critical buckt. 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 alloqed and Appendix F of Section !!! do not provide a

by NF-3231.l(s)is for stress range. Cntical buckling faulted condition load rating. This guide provides an -

stresses with normal desian margins are denved in intenm method for the determination of faulted con.

XVil-2200 of Section 111. Since buckling prevents dition ;oad rating.

" shakedown" in the load. bearing member. XVil-2110(b) must be regarded as controlling. Also, buckl. 3. Design by Experimental Stress Analysis l ing is the result of the interaction of the configuration L

of the load. bearing member and its matenal prop- While the collapse load for the experimental stress j erties (i.e.. elastic modulus E and minimum yield analysis method is defined by !!-1430 in.Appendia ll j strength 5,). Because both of these matenal prop- of Section 111, the vanous levels of service limits for

' erties change with temperature, the critical buckling expenmental stress analysis are not delineated. This deficiency is remedied by the method described in <

l I **

' Itegulatory Guide 1,8f. " Code Case Acceptability-ASME 5ec.

! tion ill Mosenals." provides guidsace for the acceptability of ASME Section 111 (* ode Cases and their revisions including Code 4. Large Deformation Case IH4. Sapplementary provisions for the use of specific code cases and their teettions enay also be provided and should be con. The design of component supports is an integral sidered when applicaele. part of the design of the system and its components.

f

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OGO l.124 2  :. UsV l

. _ _. .____,_.-..-______-____.__-.._____.__.__.-m---

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I

' A complete and consistent design is possible only lar plant condition, the stresses or loads resulting

  • 'when system /componenticomponenti 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 limier foe 'he m evaluated oc ao eintk kit, the laur.sedou is usu- plant condition.

ally valid because individual deformations are small.

However, if plastic analysis methods are employed in 7. Densitions the design process, large deformations that would re-salt in =haranaally different stress distribudons may Design Condition. De loading condition defined i by NF-3112 of Section III of the ASME Boiler and Pressure Vessel Code.

When component suppons are designed for lon6 ,

.ings associated with the faulted plant conditions. Ap- Emergency Plant Condition. Rose operating con.  :

ditions that fiave a low probability of occurrence.

pendix F of Section III permits the use of plasuc analysis methods in certain acceptable combinations Faulted Plant Condition. Those operating condi.

for all three elements. These acceptable combinations tions associated with postulated events of extremely j are selected on the assumption that component sup- low probability.

t ports are more deformation sensitive (i.e., their de-formation in general will have a large ettect on the Lev is of S evice Limits. Four levels. A. B. C. and stress distribution in the system and its components.) D. af service limits defined by Section !!! fer the de-Since large deformations always affect the stress dis- sign ofloadings associated with different plant condi.

+

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 ' lear Power plants.

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 startup, operation, hot where the change of geometry should be taken into standby, refueling, and shutdown other than upset.

account to avoid erroneous results. emergency, or faulted plant conditions.

S. Function of Supported System Operating Basis Earthquake (OBEl. As defined in Appendix A to 10 CFR Part 100.

In selecting the level of service limits for different l I

loading combinations, the function of the supported Plans Conditions. Operating conditions of the plant system must be taken into account. To ensure that categorized as normal, upset. emergency, and faulted i

( systems whose normal function is to prevent or miti-gate consequences of events associated with an emer-Pl ant conditions.

Safe Shutdown Earthquake ISSEl. As defined in j gency or faulted plant condition (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-identical) or other justifiable limits provided by the tion III.

Code should be used.

j Specified Seismic Events. Operating Basis Earth-j Since Appendix XVil derived all equations from quake and Safe Shutdown Earthquake.

AISC rules and many AISC compression equations have built in constants based on mechanical prop-System Mechanical Loadings. The static and emes of steel at room temperature, to use these equa-dynamic loadings that are developed by the system tions indiscriminately for all NF and the latest ac- operating parametets, including deadweight, pres-

)

cepted version of Code Case 1644 materials at all sure, and other external loadings, but excluding ef-

fects resulting from constraints of free end move-
tamperatures would not be prudent. For materials ments and thermal and peak stresses.

> other than steel and working temperatures substan.

tially different from room temperature, these equa- Ultimate Tensile Strength. Material propeny based

tions should be rederived with the appropriate mate- on engineering stress-strain relationship.

na Pmpenses.

Upset Plant Conditions. Those deviations from the

6. Defoeienden Limits normal plant condition that have a high probability of I

occurrence. i

$1nce component supports are deformation-sensitive load-bearing elements, satisfying the serv. C. REGULATORY POSITION l ice limits of Section III will not automatically ensure ASME Code8 Class I linear type component sup-  !

.. their proper funcuon. Deformation limits, if specified by the Code Design Specification, may be the con- e Amencan sectety of Mechanical Engineers Boiler and Preswre trolling criterion. On the other hand. If the function Venel Code. Secnon JII. Division 1.1974 Edmon. including ine of a component support is not required for a panicu. 1976 winter Addenda thereto.

y nrzQ I,124 3 L Ud' f

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ports excluding snubbers, which are not addressed or the latest accepted version of Code Case l 8

herein, should be constructed to the mies of Subsec. 1644.

tion NF or Secnon 111 as supplemented by the follow.

. ing:

  • c. Method J. When the values of allowable stress or stress intensity at te s,.w.. for a material
1. The classification of component supports are listed in Section III, the ulumste tensile strength should, as a minimum, be the same as that of the 1 88 temperature for that material may be approximated supporud components.

< by the following expressions:

2. Values of S. at a temperature t should be esti. 3, . 43 ,,

mated by one of the three following methods on an  !

inserim basis until Section III includes such values:

3* " 38= j I

where

a. Method I. This method applies to component support mr.terials whose values of ultinnate 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 allowable stress at temperature t in Section 111.

t S. = listed value of allowable stress intensity at S., = S , p"' , but not greater than S r temperature t in Section Ill where S. = ultimate tensile strength at temperature t to 3. The Code levels A and B service limits (cr com.

Ponent supports designed by linear elastic analysis l be used to determine the service limits which are related to S, should meet the appropriate S.., = ultimate tensile strength at room temperature stress limits of Appendit XVII of Section III but I tabulated in Section III. Appendix 1. or the should not exceed the limit specified when the value

.t. test accepted verston' of Code Case 1644 of 5/6 3. La substituted fer In Examples are shown S; = ultimate tensile strength at temperature t below in a and b.

tabulated by manufacturers in their catalogs or other publications a. The tensile stress limit F, for a net section as Si, = ultimate tensile strength at room temperature cdited in XVII-C ' a. .M Secti.m !!! should be 4 tabulated by manufacturers in the same pub

  • the smaller value of 0 nS, or 0.55,, at temperature.

lications. For net sections at pinholes in eye. bars, pin.

b. Method 1 This method applies to component connected plates, or built.up structural members. F i support matenals whose values of ultimate tensile as specified in XVl[-l*llibe should he the smaller value of 0.45S, or 0.375S. at temperature.

strength at temperature have not been tabulated by their manufacturers in any catalog or publication.

b. The shear stress limit F for a gross section as i S, specified in XVil-2212 of Section III should be the S. = S.,

3,,

smaller value of 0.4S, or 0.33S. at temperature. l where Many limits and equations for compression S. = uitsmate tensile strength at temperature t t strength specified in Sections XVil-2214. XV11-l be used to determine the service limits 2224 XVII-2225. XVII-2240, and XVII-2260 have i S., = ultimate tensile strength at room temperature built.in constants based on Young's Modulus of i tabulated in Section III, Appendix !. 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 111 Appendix 1. or the the appropriate Young's Modulus unless the cr.nser.

latest accepted version' of Code Case'1644 vatism of using these constants as specified can be dem nstrated.

S,, = minimum yield strength at room temper.

I sture, tabulated in Section !!I, Appendix I,

4. Component supports designed by linear elastic analysis may increase their level A or B service limits
  • If the functico of a componen support is nos required during a according to the provisions of NF-3231.l(a). XVII-piant condition, the desaga limits of the support for that plant con. 2110(a), and F-1370(a) of Section 111. The increase cition need not be sationed, provided excessive deflection or faal.

ute of the support will not result in the loss of function of any of level A or B service limits provided by NF-

! other safety reinied sysiem. 3231.l(a) is for stress range. The increase of level A

i. i24 " 4,
u. M0 t
.y y ( -

,, ' Section III aivided by 1.7 should not be exceeded for

i l ' service cr B service li-thebep
ovided limits should the smallerby F-1370(a) factor of 2 or for level D supports designed by the esperimental component 1.167545,, if Se ai 1.25, or 1.4 if S. 4 1.25,, stress analysis method.

.where 5, and Se are component support material 6. Component supports subjected to the system 7

  • Propmuss at waperamre.
mechanical toedings associased with the'einergency

.However, all increases (i.e., those allowed by plaat conditica should be designed within the follow. ,

. NF-3231.1(a), XVII-2110(a), and F-1370(a)] ing design lumies except when the nortaal IImaction of

, should always be limited by XVII-2110(b) of Secdos the supported system is to prevent or mitignes the III. The critical buckling strengths defleed by consequences of events associated with the emer.

XVII-2110(b) of Section III should be calculated gency plaat condition (as which time Regulatory using maternal properties at temperature < Dis is. Position 8 applies):* 8

. crease of level A or B service limits does not apply to l_ a. The stress limits of XVII-2000 of Secnon III '

1 limits for bolted comaections. Any lacrease of linu,ts and Regulatory Positions 3 and 4 increased accord.

for shear stresses above 1.5 times the Code level A ing to the provisions of XVil-2110(a) of Section !!!

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(s) is more than 25, or S, it should be linear elastic analysis method.  ;

] limited to the smaller value of 25, or Se unless it can

b. The emergency condition load rating of NF-i be justified by a shakedown analysis.

3262.3 of Section 111 should not be exceeded for

5. Component supports subjected to the combined component supports designed by the load rating j- loadings of system mechanical loadings associated method.

with (1) either (a) the Code design cordition or (b) j . The lower bound collapse load determined by the normal or upset plant conditions anu il) the vib-3ygg_g.00 . adjusted according to the provision of

ratory motion of the g8E should be sy, ned within XVI!4110ta) of Section ill should not be exceeded

, the following firnits. .

for component supports designed by the limit analysis  ;

i a. The stress limits of XVil-2000 of Section til method.  ;

~

j and Regulatory Position 3 of this guide should not be gg gg g j exceeded for component suppons designed by the Section ill divided by 1.3 should not be exceeded for i linear elastic analysis method. These stress limits may be increased according to the provisions of component supports designed by the experimental NF-3231.l(a) of Section DI and Regulatory Position stress analysis method.

i l 4 of this guide when effects resulting from constraints 7. Component supports subjected to the combined '

j 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 m tion of the SSE, and (3) the dynamic system i b. The normal condition load rating or the upset condition load rating of NF-3262.3 of Section ill I adings associated with the faulted plart condition i

should not be exceeded for component supports de.

should be designed within the following limits except q when the normal function of the supported system is f signed by the load rating method.

to prevent or mitigate the consequences of events as. .

j c. De lower bound collapse load determined by sociated with the faulted plant condition (at which  !

XVII-4200 adjusted according to the provision of time Regulatory Position 8 applies)

i XVII-4110(a) of Section ill should not be exceeded for component supports designed by the limit analysis De lis d XVIM000 d Mm III and Regulatory Position 3 of this guide, increased ac.  !

cording to the provisions of F-1370(a) of Section ill

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

~

t

's6nce component apewis are deformenon wounv. n ine linear elastic analysis enethod.

r- performance of inser service regewomenes. seeiefyins enese cnione f sen nm enswe ines ineir amenesse regenomenne win a reitined. .b. The smaller value of T.L. x 25/Se or T.I.. s  ;

i Any de#weenen umm spairled by tw eenen specif6eemen mey 0.75/5. should not be exceeded, whete T.L., 5, and j w sonnostias and sneeld be samef6ed. S., are defined according to NF-3262.1 of Secnon l 111, and 5'. is the minianum ultitness tensile suength a Iine a N 4em of the de d the material at service mmperature for component usan men mene owe ines meinees seed tw ine eeniym of in supports designed by the load. rating method.

[ .,

(","j,*iE"' ,'"*,,',7"' gT, E 'y'",,',",,'g',',",' XVll-4200 c. De lower bound collapse load determined by adjusted according to the provision of

! iione in ine synem or componense enemed be conumered in ene l' Jewsa of compoaea wppwis. F-1370(b) of Section ill should not be exceeded for 1.124 5 ') 061 l

_~_-- _.-___ _ _,_ _ _ -_ _ _ _ _ _ _ _ _ _ _ _

~

component suppens 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 The purpose of this section is to provide guidance Section !!! should not be exceeded for component t applicants and licensees regarding the NRC staff's suppotts 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 scribed in Regulatory Position 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 rrgulatory 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 loadir.; enmhinations described in Regulatory perunent portions of the application will be evaluated Positions 6 and 7. on the basis of this guide.

l

1. : 3.n