ML20094E938

Affidavit of M Walsh in Support of Case Answer to Applicant Statement of Matl Facts as to Which No Genuine Issue Exists Re Consideration of Damping Factors for OBE & SSE Loading Conditions

ML20094E938
Person / Time
Site:	Comanche Peak
Issue date:	08/04/1984
From:	Mary Walsh Citizens Association for Sound Energy
To:
Shared Package
ML20094E903	List: ML20094E895 ML20094E921 ML20094E938 ML20094E956 ML20094F012 ML20094F042 ML20094F058 ML20094F082 ML20094F149 ML20094F187
References
OL, OL-1, NUDOCS 8408090426
Download: ML20094E938 (13)

Text

. - . _

bNITED STATES OF AMERICA NUCLEAR REGULATORY COM ISSION

~

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of TEXAS UTILITIES GENERATING Docket Nos. 50-445-1 and COMPANY, et al.- '

50-446-1 (Comanche Peak Steam Electric Station i Station, Units 2-and 2) l CASE'S ANSWER TO AtPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE REGARDING APPLICANTS' CONSIDERATION OF DAMPING FACTORS FOR OBE AND SSE LOADING CONDITIONS in the form of AFFIDAVIT OF CASE WITNESS MARK WALSH

1. Applicants state:

" Piping systems are not ' active systems,' as that term is used in Regulatory Guide 1.61 (Iotti Affidavit at 3)."

I dispute this point. Since these piping systems are supporting active valves and components, the systems must be evaluated as though they were active systems using the appropriate damping factor to determine the load induced to the active valve or component.

The basis for my position is contained in Regulatory Guide 1.48,

" Design Limits and Loading Combinations for Seismic Category 1 Fluid System Components," which states in pertinent part (.page 1.48-5):

"4 . - Active ASME Code Class 1 pumps and valves that are designed 4

by analysis:

"a. The design limits specified in NB-3222 of the ASME Code should not be exceeded when the component is subjected to either (1) concurrent loadings associated with either the normal plant 1

J 1-

! 1

. 8408090426 840806 .

PDR ADOCK 05000445 G PDR

_ - - _ . _ . _ . - _, ~ . - . _._ _ _ ____,_._ _ _ - - , __

condition or the upset plant condition and the vibratory motion of 50 percent of the SSE, or (2) loadings associated with the emergency plant condition, or (3) concurrent loadings associated with the normal plant' condition, the vibratory motion of the SSE, and the dynamic system loadings associated with the faulted plant condition." (Emphasis added; footnotes omitted.)

For this reason, I disagree with the Applicants' response under cover letter dated 6/28/84 to CASE's discovery question, which stated (bottom of page 2):

"(1) Mr. Walsh questioned why it is appropriate to use damping factors from Regulctory Guide 1.61 for piping, when active valves and pumps which are on the piping are qualified for OBE damping factors only. In response to this inquiry we provide _the following response:

"It is incorrect to assume that, because active valves or pumps may be located at a random point in the piping run, Regulatory Guide 1.61 (Table 1, Note 2) is intended to penalize the entire piping system by the use of lower damping factors simply because of the existence of the active component. The higher damping factors permitted for piping analysis for the SSE may be used to establish end loads for the active components. However, valves and pumps are normally specified and procurred prior to piping analysis and are qualified for more stringent spectra than the piping.

Thus, spectra are furnished for those active components directly, which will reflect the lower damping factor of the OBE."

Applicants' statement that ". . . valves and pumps . . . are qualified for more stringent spectra than the piping" is also in error, i

as confirmed in the attached May 25, 1982 letter to R. E. Ballard of i

Gibbs & Rill from J. R. Johnson, Project Mechanical Engineering, TUSI, and received by CASE from Cygna on discovery in regards to seismic I

analysis of valves. As indicated in that letter, there are valves that cannot be considered rigid. In regard to test results on certain ITT-

[

f l Grinnell valves, the letter stated (page 1, first paragraph):

i l

l r

i ~

"The valves were to have been designed for 33hz. and the test indicated that the air operated valves could only reach 20 hz. and the motor operated valves 27 hz."

To correct this problem and associated problems, three options were considered as shown below (last two paragraphs, page 1):

" Based on the resonant search test results, Kamel suggested that we look at three options. Option number 1 was to have ITT-Grinnell put gusset plates on the valves to increase the frequency to 33 hz. Option number 2 was for the site to add external bracing by means of valve supports and clamps. Option number 3 was for the stress analyst to review the valves with their given frequency and determine if the stress analysis would still be acceptable. It was mutually agreed upon the Option number 3 would be tried first.

"TS/SSAG has reviewed the stress analysis reports for 1-HV-5157 and 5158 and have found them to be acceptable as is. The 1-CT-135 and 136 valves by comparison should be all right, however; we have not actually verified them at this time. The valves and piping are currently being rerouted and once the new routing is complete, SSAG will verify their acceptability."

It further appears that as of May 3, 1983, option number 3 had actually been incorporated into the design specification (see attached May 3,1983, letter from Robert E. Ballard, Project Manager, Gibbs &

Hill, to J. B. George, Vice President / Project Gen. Mgr., TUCCO, and attached Design / Engineering Change / Deviation Request No. S-2716).

From the above-referenced document, it would appear that those valves were specified to be rigid (frequency greater than 33hz.) but were procured using a less stringent (rather than more stringent)

criteria.

l l

l 3

1

=. . - . ._-

4 4

4

. 2. Applicants state:

" Applicants use 1 and 2 percent critical damping response spectra for the OBE and SSE evaluations, respectively, for small diameter (12" and under) piping systems. These are the damping factors set forth in Regulatory Guide 1.61. (Iotti Affidavit at 3.)"

I question this statement.' In the 7/16/84 Cygna Report (" Final Report, Independent Assessment Program of Comanche Peak Steam Electric Station (Phase 3)," prepared by Cygna Energy Services). Observation No. PI-00-03, sheet 1 of 1, states:

"The seismic analyses of the Main Steam piping outside Containment used response spectra curves at 2% and 3% damping for 1/2 SSE and SSE, respectively. The modal analyses for these systems show that the primary response is located in the 8" relief lines. This size piping requires the use of curves at 1% and 2% damping."

(Emphasis added.)

It is also noted that Cygna considered this to be " Extensive" and not an isolated matter.

It would appear to me that Applicants are attempting to mislead t

the Licensing Board. (See also comments in answer 1 above.)

3. Applicants state:

"The piping seismic analysis for support CS-1-235-067-C41K used damping i values of 1 and 2 percent critical damping. (Iotti Affidavit at 3-4)."

In Dr. Iotti's Affidavit (page 4), Applicants claim that CASE was apparently misled by a statement in the NRC Staff's SIT Report (NRC Staff. Exhibit 207) and that the SIT was not clear regarding the use of 2 and 4 percent damping factors. If an error was made in the SIT i Report, it appears to me that the proper way for it to have been i

l 4

- , - . - . - -_.-._..,,_.,r~ . , _ . - , . , . , , , _ , _ . . - , . . ,_.y,.__-_-...w .. .-,..,,,-,,,mm,,,, _

, ,.__._3 v. ., ,,_, , - ,.m_.,,,_%

5 handled was for Applicants to so advise and, if the Staff agreed, for i

the Staff to officially notify the Board and parties that a change should be made in the SIT Report. To my knowledge, this has not been done. Because of this, at this point in time, we don't know whether what the SIT saw was the use of damping values of 1 and 2 percent or 2 and 4 percent. ,

It appears to me that the possibility exists that Applicants are n

using the coupling factor as a cover-up for the use of the wrong damping factors. This possibility is more plausible because of Cygna's finding (see item 2 above). Since Dr. Iotti was not actively involved (as far as I am aware) with these issues at the time of the SIT Report, he would not know of his own personal knowledge what values were used at that time.

4 Applicants state:

" Piping stress analysis problem 1-41, which includes support CS-1-235-067-C41K, used 2 and 4 percent critical damping for calculating the coupling factor. This assumption is conservative. (Iotti Affidavit at 4-5.)"

There is not sufficient documentation attached to Applicants' Motion for Summary Disposition to support the conclusion that Applicants' assumption is conservative. Applicants' FSAR (Applicants' Exhibit 3), Section 3.7N.2.7, discusses the piping. stress analysis. I have not reviewed the entire stress analysis problem, and am unable at this time to either confirm or deny that the assumption is 5

9 .

conse rvative. However, it should be noted that the coupling factor is .

only used when frequencies between adjacent modes are within 10% of one another. If there are no modes with frequencies within 10% of one another, the coupling factor is not used and is immaterial.

In addicion, the equations where the coupling factor is utilized will require the use of the correct ar appropriate damping value for the coupling factor to be conservative. That is to say, in the equation in Applicants' FSAR section 3.7N.2.7, equation 3.7N-29, the damping value for the response of mode 1 and mode 2 must be the lower damping value and it would be conservative to use a higher damping value when calculating the coupling factor. I question whether or not this was actually done because usually most of the analyses are done on a computer where a damping value is input into the analysis, and the same damping value is used throughout the analysis and not changed for one particular calculation.

5. Applicants state:

" Applicants use different seismic spectra for OBE and SSE events, as appropriate for the two types of events. Use of these spectra is not related to the selection of damping factors. (Iotti Affidavit at 5.)"

I do not disagree with these statements, except as to whether or not the spectra used are actually appropriate, as discussed elsewhere in this answer.

6

6. Applicants state:

" Damping factors other than those specified in Regulatory Guide 1.61 were used for the Westinghouse reactor loop configuration. Use of these different factors was justified by analyses, as an exception to Regulatory Guide 1.61. Iotti Affidavit at 5-6.)"

Since I have not reviewed the analyses used to justify use of the different damping f actors for the Westinghouse reactor loop configuration, I can neither confirm or deny whether or not their use was, in fact, justified, as Applicants claim.

It should be noted, however, that according to Applicants' FSAR (Applicants' Exhibit 3), at 1 AN-34, indicates that the only system which used higher damping values than listed in Regulatory Guide 1.61 is the reactor coolant loop. Therefore, the applicable damping factors listed in Regulatory Guide 1.61 are to be used for all piping systems except the reactor coolant loop. This is important insofar as the rest of this answer is concerned.

Attachments:

5/25/82 letter to R. E. Ballard, Gibbs & Hill, from J. R. Johnson, Project Mechanical Engineering, TUSI, regarding test results on certain ITT Grinnell valves (see answer 1, page 2) 5/3/83 letter to J. B. George, Vice President / Project General Manager, TUCCO, from Robert E. Ballard, Project Manager, Gibbs & Hill, regarding Design / Engineering Change / Deviation Request No. S-2716 (see answer 1, page 3) 7

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 through CASE President, Mrs. Juanita Ellis, 1426 S. Polk, Dallas, Texas 75224, 214/946-9446.

My qualifications and background are already a part of the record in these proceedings. (See CASE Exhibit 841, Revision to Resume of Mark Walsh, accepted into evidence at Tr. 7278; see also Beard's 12/28/83 Femorandum 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 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 statements made by Applicants. ,

0WF L .

(Signed) Mark Walsh STATE OF TEXAS On this, the f. G day of 8 - w d , 1984, personally appeared Mark Walsh, known to me to be t,h/ person whose name Ls subscribed to the foregoing instrument, and acknowfedged to me that he executed the same for the purposes therein expressed.

Subscribed and sworn before me on the #A day of 6,4ad ,

1984. #

N / <.. . s > A $ ,i n s Notary Public'in' and for' ~the

~

State of Texas My Commission Expires /g /4,//</

'f .,

C , SM Ma-r-o MS-24 4 'rm, UchsA, MS-Coy'

Incom;7 rEXAS UUES SERVICES EC.U'Cak.d/ A-

p. o. sox teos

• OLEN ROSE. TEXAS teos3 O Ptte

' o R E u EI v c. w, K.B 4 7,Pg)'"/

4 l

CPPA #19,525 l May 2f, 1982 JUN 7 1982 /dion , *

(Sc. ( /:g N

! h h 'A1.'d.

393 Seventh Avenue

@ css & = %

b- ffEdue 5: W/

/

I New York, N. Y. 10001 i Informtio3 h4ceSSca.

COMANCHE PEAK STEAM El.ECTRIC STATION Yo SFefa.re, DECtus

ITT-G RESONANT SEARCH TEST PROCEDURE 1

NUMBER NSC/RS-001 CP-0208 and CP-604 Og,g g g -

\

j

Dear Mr. Ballard:

@BlEOSW On May 10,1982 Mr. Seb Marano and Mr. Kamal Bandyopadhyay of G & H and Mr. Harlan R. Deem of TUSI held a telephone conference to discuss the test results on the subject ITT-Grinnell valves. The

' resonant search test perforined by ITT-G. failed for both the air l operated and motor operated valves. The valves were to have been

designed for 33hz. and the test indicated that the air operated valves could only reach 20 hz. and the motor operated

• valves 27 hz.

The following is a list of valves which ITT-Grinnell has yet to qualify:

1-HV-5157 Air Operated 26hz.

1-HV-5158 Air Operated 20 hz.

2-HV-5157 Air Operated 20 hz.

2-HV-5158 Air Operated 20 hz.

1-CT-135 Motor Operated 27 hz.

1-CT-136 Motor Operated 27 hz.

2-CT-135 Motor Operated 27 hz. -

. 2-CT-136 Motor Operated 27 hz.

Based on the resonant search test results, Kamel suggested that l we look at three options. Option number 1 was to have ITT-Grinnell l put gusset plates on the valves to increase the frequency to 33 hz.

Option number 2 was for the site to add external bracing by means i of valve supports and clamps. Option number 3 was for the stress

! analyst to review the valves with their given frequency and determine i if the stress analysis would still be acceptable. It was mutually i agreed upon that Option nisaber 3 would be tried first.

i T5/55AG has reviewed the stress analysis reports for 1-HV-5157 and 5158 and have found then to be acceptable as is. The 1-CT-135 and 136 valves by comparison should be all right, however; we have not actually verified them at this time. The valves and piping are

• currently being rerouted and once the new routing is complete, SSAG will verify their acceptability. .

4

---<,,----,-.,.rve,-4m---.,-.----.,,--m_.,m--~ny---v-,. .wm--n-.m-...m,r-.n-,-,.ww , ~ . . . . , - , . - - - - - - - ~ , . . . , - . ~ - ,

g CPPA #19.525 Page 2 of 2 TUSI recommends that G & H proceed with obtaining necessery information from ITT-G in order to obtain final approval. TUSI will provide to G & H the loads which are applied to valves by stress analysis. The loads for 1-HV-5157 and 5158 are between 2G and 3G.

We do not have the loads for 1-CT-135 and 136 valves at this time.

G & H will review the loads from SSAG for ITT-G valves and verify that the valve design parameters are still valid. G&H ad11 then prepara a DECD to aumend specifications MS-020B and MS-604.

TUSI will issue DCA to specification MS-0208 and MS-604 when we have reviewed and accepted G & H's DECD. -

It is imperative that the remaining work to qualify these valves be accomplished in a timely manner. The valves are waiting on shipment to the site and need the DCA to the specification before they can be released.

Very truly yours, ,

. R. Johnson Project Mechanical Engineering JRJ: HAH:$HRD:ery ..

cc: ARMS M. R. McBay J. T. Merritt W. O. Handley G. Krishnan D. Hicks e

ww,,--

~ O

• 860.2716,

<P REBoh.1.xd/MS-20B, XOMoor .

wrs= mayo dhyay, O TGOING, KSchlaskMSMilla@r Bond 3 *v4'-4 i

May 3, 1983 GTN- 65374 Texas Utilities Generating Company

- Post Office Box 1002 -

G1en Rose, Texas 76043 Attentions Mr. 1. B. George Vice President / Project Gen. Mgr.

Gentlemens TEXAS UTILITIES GENERATING COMPANY COMANCHE PEAK STEAM ELECTRIC STATION

~

G&H PROJECT NO. 2323 O 09410 DEVIATION REQUESTS DE/CD S-2716, Rev.1 ,

. SPECITICATION 2323-MS-203 Enclosed for your review is a copy of Design Engineering Please Change Deviation Request number S-2716, R.1 inform us of your disposition of this request.

3 All recipients of this letter are advised that authorization l from TUSI is required before proceeding with the action noted i

i herein.

very truly yours, I

GIBBS & HILL, Inc.

Pa.m_,s.

- 8 .

REBa e .

, _ .r . 1 tt. . .nt .

CCs ARMS (B&R Site) OL + OA ,

{

I '+. a I

i

O .

1 M

g orm

~

[cJ'?

'. nesrewerwerwernrwa

e. *

. cnANer/eevrxeren areurst l

.f~

• i% O woc:.EAn sArErr-azurEn l-l mon-nuer.Exn sArErr AzLArzo - l_~l won-nuCLExa sArErr mzur QA PROCAAM APPLICABLE b'\

11-2323-056 S-2716 1 G&u. Job. no. nE/Cn nequest no. new.

I asquested By: G& E l[l C11ent lZl Field l[j ve ndo r l[l

~

FROM CPPA-19525 (JRJohnson) asterence Docueent AM Memo AM M-4379 a v. -

note 2/17/83 coeveenta Agreet.de GsH Specification 2323-MS-20B, Rev. 1 & Addendum 1 l

ocscuterreN or enasce/ervrArrow arentstro l See attached ENCrNEEurWC JUSTrPrCA? ROM POR AScv2:

The motor-operated valves have a resonance frequency below 33 Bertz. -

KK}s J O REQUEST FREPAREn BY K.K. Ban opakh, yay Title Sr.Eng'r Date 4/27/83 INTERDISCIPLINE REVIEWS Design Reviewer / Engineer comoletes mis Section Instaals - ca t e

1. Is this a significant deviation or arror7 YEs l _~ l NO l",

Meehenical MM Ygl %I 2. Is this a recurring deviation or error?

TES l ~ l NO l~'

tiectrical M 4/2h3 Desion Reviewer comoletes Wie Section OA Design Verification: Approved l l

stM Not Approved l _~ l N1 .4 *LV y s A w 4u mw # w 21 +1 Design Review Dig. R.%h ~, 'Date 4h7/f5 l

Job Engineer comoletes this section h

1. Is change potentially reportable under 10CTR217 YESl[l NO lZl

2. Is change in compliance with BTP-ET33 11-17 ~

TES l 2 l 30 l _~ l MA l _~ l

3. Applicable DCRP Date CHANCE /ervrArrow RrectST: j Approved l Not Approved lZl Approved l Mot Approved l_l J. E. Date Project Manage / /w fd_Date f / l # #

~

. . emmmmmmme _- - -

/. [U.

1 n+..

- 1 i." l

, .3 DESIGN / ENGINEERING CHANGE / DEVIATION REQUEST S-2716 )

, Description of Change / Deviation Requested l Revise GEH Specification 2323-MS-20B, Rev. I a'nd Add. 1, -

as follows:

~

Revision 1 - Page 3-31, Paragraph 3.7.9.3.c (Addendum 1, cace 5 of 7, Item 13, Renumbered Paragraph 3.7.9.4.b) -

Rewrite the entire paragraph as follows:

If the valve assembly has a fundamental natural frequency of 33 Hertz or-greater, the manual, motor-operated and self-actuated Saunders patent type steel valves shall be des ~igned to withstand seismic forces resulting from accelerations of 3g in each of the two horizontal directions'and 2g in the vertical direction caused by the Safe Shutdown Earthquake (SSE). The corresponding. Operating Basis Earthquake (OBE) g-values shall be 2.25g and 1.5g. If the fundamental natural frequency of the valve assembly is less than 33 Hertz, the Seller shall provide all natural frequencies below 33 Hertz and applicable mass and stiffness data. This data will be incorporated in the supporting ~

pipe system dnalysis, and the above mentioned g-values will be verified (by others). If the resulting acceleration lev 41s exceed the g-values mentioned above, the Seller will be so notified,-

and the Seller shall qualify the equipment for the new g-valuesy otherwise, abov listed g-valuee shall be ussa for qualification j

@ of the equipment. In all cases, the two (2) horizontal and vertical seismic accelerations shall be assumed to act simultaneously, with the resulting stresses, deflections, etc.,

obtained by the (SRSS) square root of the sum of the squares technique. The equipment function shall not be impaired by the SSE.

Revision 1 - Pace 3-31, Paragraoh 3.7.9.3.f (Addendum 1, pace 6 of 7, Item 14, Renumbered Paragraph 3.7.9.4.e) -

. Delete.the entire paragraph.

0 i

I

!O -

.I I

i

. . . - - - _ _ _ - , _ _ _ _ , . _ _ _ . , . - - , , _ , - , _ _ _ . - _ - - - . _ __.___._ _ _ -