ML20096B994
| ML20096B994 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/27/1984 |
| From: | Doyle J, Mary Walsh Citizens Association for Sound Energy |
| To: | |
| Shared Package | |
| ML20096B875 | List: |
| References | |
| OL, NUDOCS 8409040448 | |
| Download: ML20096B994 (33) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOA [ihD In the Matter of ,
l I .M SEP~4 TEXAS UTILITIES GENERATING l DocketNos.50-44k2__.
COMPANY, et al.- l and 50-446-b (
(Comanche Peak Steam Electric Station
' 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 SAFETY FACTORS in the form of
-Affidavit of CASE Witnesses Mark Walsh and Jack Doyle MESSRS. WALSH AND D0YLE:
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 talking about apples; Applicants in effect htve 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 of 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 46.
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&- . . at
- 1. Applicants state:
" Seismic loading is the'_ design determining force for virtually all
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piping supports of concern at CPSES. Affidavit of J. C. Finneran, R.
C. Iotti and -R. D. Wheaton Regarding Safety Factors (' Affidavit') 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 L1!.
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 Gaps 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 App 1Leants 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.
/1/ We also note that Mr. Wheaton's resume includes, under " Selected Publications" on page 3, two publications in June 1934 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).
See also Pages 1 and 2 of Affidavit.
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- 2. Applicants state:
"A conservatively quantified margin of safety associated with some
,. - factors affecting seismic design .is on the order of 46 (H. 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 ( H. at 11-12)
"d. Site-Structure Interaction Analysis - 1.5 ( H. at 18-21)
"e. Damping - 1.38 (Id,. at 22-25)
"f. Uncoupled Analysis - 1.1 ( H. at 25-26)
"g. Envelope Support Excitation Approach - 1.1 (H. at 27-28)
"h. Broadened Floor Response Spectra - 1.1 ( H . 28-29)
"1. Orthogonal Input Motions - 1.1 ( H. at 29-30)
"j. Modal Combintion Rules 2 ( H. 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) ( H. at 36)
"m. Dynamic Reserve Strength - 1.5 ( g at 37)"
We disagree with this statement, which is very misleading. The Applicants (beginning on page 2, last 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 f actors 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 i
required in the working stress design, which CASE referenced in their 1
Proposed Findings. (See CASE's Proposed Findings of Fact and 3
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4
. Conclusions _ of Law (Walsh/Doyle Allegations), pages I - 6 through I -
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' Applicants are committed.
In. CASE's Proposed Findings, CASE argued that the-factor of safety against the allowable ~ stress was being eroded. ~The loadt that produced the stresses were not argued by CASE in 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 argue that the temperature within the containment ~ should be 600 degrees F. during a LOCA (which might be
)
argued due to the t'emperature 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 required damping facters chich the . applicants are committed to use was too liberal.
What CASE has argued in the past is that the safety factor has 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;
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(4) Not considering the consequences of wall-to-wall and floor-
- to-ceiling supports; (5). Not considering friction loads; 4
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'(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.co 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:
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"If the one category just mentioned -(including code margins raised 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 of 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 surf ace, and this was done because of a field change. It will be noted that all these changes 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 (Id. at 37-38)
"d. Redundancy (Id. at 4-5)"
See answer 2 preceding. In addition, throughout their Affidavit, 6 j l
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- e. 7s 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
'thoroughlyreviewthe44referenceddocumentsf2/.
MR. WALSH:
One of the most striking aspects of those References in Attachment 3 which _I have had time to quickly sean' 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 eva'luated:
(1) ". . . Rigorous nonlinear dyanmic analysis methods are valuable tools in seismic analysis and design when combined with engineering judgement, careful detailing, and auality construction workmanshin. . .
(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
]2/ Applicants supplied CASE with only one copy of each of these 44 documents, and Mr. Doyle has not seen any of these documents.
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t apparently helped prepare, was referenced in Applicants'
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. Affidavit on pages 6 and 10. (This was one of the more recent References which'was included in Applicants' list.)
It states, in part:
"InL 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 practices.
Design and construction errors are particularly troublesome.
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'l-8, emphases added.)
(3) Another important document referenced by Applicants (page 24 of Affidavit) is Reference 16, NUREG/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 NPC 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., arising from dead load, live load, thermal effects, etc." (Page.3 of Report, emphasis added.)-
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"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 dangerously u,nsafe." (Page 5, emphases-added.)
"Obviously appropriate damping 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 important 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 properties 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 - suf ficient 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, f astening, and actual material oronerties to be sure that the resistance available is adequate to meet th'e deannds of the upgrded design requirements." (Page 38, emphases added.)
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 i
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a considered, lack of consistency,'use of improper. values, intimidation of'QC inspectors,' inadequate'QA/QC techniques
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_ '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 helpe'd prepare - -
warns ~aga' inst, and Applicants are now' attempting-to convince the-Board that safety factors exist which are in actuality inflated.
~Throughout Applicants' Affidavit, 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 capacity well in excess of its design value. This is true even in those cases, such as petro-chemical plants, where only minimal attention was originally paid to seismic issues. In the case of 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 of seismic capacity. The-result is a seismic reserve margin, or added safety factor, that far. exceeds original design targets."
(Emphasis added.)'
And on page 9 of their Affidavit, Applicants state:
" Time intervals of such a magnitude are approaching a geologic i time scale and are probably physically unrealistic for engineering purposes. Nonetheless, current nuclear industry practice results in a seismic' ground motion that is 'a_t,least t a factor of 2.4' times the design objective (Reference 4) (underline included in reference)." -(Additional emphasis added.)-
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%; l In briefly scanning the same Reference 4 (the 1983'ASCE Report) discussed in the preceding on page 7, I found the I Yfollowing 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, entphasis added.)~
It should be noted that this current nuclear industry.-
practice recently. the untempered reliance by the nuclear industry-
~
on probabilitic risk assessments (PRA'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 f4/, there was a d'scussion i regarding the examination of accident precursors, and the following statements were mado 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 adequacy. 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 virtually 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:
]_4/ .See Attachment S hereto.
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". . . 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 fall a pipe through seismic excitation . . . "
However, this 1983 report f5/ 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 demands vary considerably from system to system for complex piping configurations,. leading to difficulties in defining generic reserve margin factors 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. ...
. . . follow up work and sensitivity studies are ' continuing 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.
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l (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 Applicants'
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 Committee and Technical Committee on Piping Systems, are developing an overall positica 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 from 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 ASME 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 intended 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 properties. . . 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. . .
i l 13 i l
I
. .o "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 metheds. . .
"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 will 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 Proceduros 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 statements 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 w sl
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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 TUCCO 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.
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}, y y; -TheApplicants,41nitheir'Affidavitatpage33,'claimthatthey haveahigher'fachorof?safetydue.tothelasticdeamplification,and s ,
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c, theyjrefer.'to Reference 32 to support that statement. Mcwever,
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- 4. Applicants.scate:- ,
"Numerousstudieso'the.effectsofseismiceventsonmajor.sbructures '
support the cobelusion that seismic design' margins are significant.
M .'at Attachment 2."
Applicants' state on page 5 of their Affidavit: ,
". . . This -is- borne out by observations conducted at several plants. subjected'tc severe earthquakes.- It is to be noted that these N ants were gt, built withicly stringent GA requirements applied to ' nuclear . plants. A summary of these observations is w provided in At'tIchment 1 (sic -- shouhd be' Attachment 2)."
't r It should be noted cliat throughout their Affidavit, Applicants do 4 -
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]6/ Referred to on page 34 4 cf Applicants Affidavit: " Seismic Analysis Methods for' the Systema %'c' Evaluation Rrogram," UCRL-52528, Lawrence Livermore Laboratory, Liltermoral California, July,1978, by T. A. i Nelsow ,
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' Attachment 2 to Applicants' Affidavit states: ' ". . .-Several examples of these events are discussed in References 37 through 41."'
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To the best of my knowledge, CASE has not yet received Reference 37; we have received - the rest, however.
In their-discussion of References 37 through 41, there are certain
' things which the Applicants failed to state. For example:
Reference 38 (El Centro Steam Plant, discussed on pages 1 and 2 of
. Attachment 2 to Applicants' Affidavit):
It was concluded 1that highly damped soil springs reasonably ref1ect the forces induced on the building (page xvi). Comanche Peak
~
does not have the same characteristics 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 anchored 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 compare Comanche Peak with this report, and to do so would be unconservative.
One further note is that damage was done to the piping system during this earthquake (page 1); that is, the cooling water piping line was damaged, .he water treatment line and the hydrogen cooling water line were damaged (page 9). In addition, many mechanical equipment supports l l
were damaged; for example, air-actuated valve operators, heat
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. with neta designs due to plastic-deformations. (Page 10.) . Unit 4 was-t , ... . .. . .
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out: df fservice- for twolhours, so' that plant personnel could inspect 'the V
damags.!fUnit.3~wasirestoredtoseevice>within'15minutdsafterIthe-
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-main shock.' 'Only by exp'edient plugg'ing oi leaks'was-Unit 3 kept in
< b service. ' Althcugh' Unit'.4 was .back:in service within two hours, it was taken out of' service within thrEe hours'to make the repairs. (Page 1.). .
q One must'rememberathat thib was'not a nuclear powee, plant'and all the-
't repairs'could)be.m'adewithoutanyriskduetoradioactivity.
Reference 39 (discussed on pages 2 and.3 of Attachment 2 to
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s ~Apg.11 cants' Affidavit);g Thisis'i'svery brief report by Westinghouse regarding the Diablo
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. . 61 Canyon plant which is based on the information about the El Centro
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' plant-(which Is discussed in detail.in Referenea 38).
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Reference 40'(discussed on page 3 of Attachment 2 to Applicants' Affidaivt): y
,This report states.that in the mill bdildings, designed for about 0.15g'with x-bracing, there was a substantial amount of failed x-bracing', usually at the bolted connections, and there was also some bending.and stretching of some anchor bolts. The plant had toppled
-bins and conveyors, twisted crane rails / cracked walls, cracked valves, displaced pipelines and supports, broken staan and water mains, dislodged equipment. etc. The reason for these damaged plant items was Jinadeqsate seismic considerations. Asrpointed'out in the report,
- comparisoddweredifficult.- This plant was out of normal operation for n ,
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. .6 days. l(Page D35.23) .It must'be. remembered that this-was not a nuclear power plant where radioactivity 'could have jeopardized the:
~
L
.' repairs and 'the -public health-and safety.
Reference 41.
- Unless I have overlooked it, this does not appear to'be addressed
~
-atzall-'in Attachment 2 to Applicants'. Affidavit. This was~a_very short
-paper'prinsentedin'198 don."SeismicPerformance.ofPipingin'Past'
. Earthquakes." ' ItL briefly discusses severa1 ' 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 of.their Affidavit (discussed in the preceding),' Applicants refer to the' " stringent GA 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 areas of contention in these proceedings, and we challenge this implication.
' 5.- Applicants state:
" Loads from sources other than a seismic event (i.e., static 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, Land 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."
19 G
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- I strongly disagree with Applicants' representations. See
' discussion on pages'16, 17,.and~18 of CASE's 8/29/84 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. See also CASE's 10/13/83 (1) 1 Motion to Add A New Contention, .(2) Motion cfor Discovery, and (3) Offer of Proof.
- 6. Applicants state:
"Many safety margins which apply to seismic-disign apply equally well to static and other dynamic loads. Id "
'As shown in the documents referenced in answer 5 above, the factor of safety or the Applicants' ability to predict the behavior of a piping. system for.a hydrostatic and hot functional' test is less than what normally would be desired. Equally important is the poor showing of the predictability of the Hot Functional Test (HFT), and the Applicants are rerunning some of the tests. The Staf'f will not'be able
-to tell the Applicants to' perform a seismic test, which is one test which the Appilcants 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 /]/.
Were Applicants able to convince the Board and the NRC Scaff that
- it is permissible to ignore all other design loadings (because of l
[ /]/ Affidavit at page 3: In that seismic loading is the design determining l- ' force.for virtually all piping supports, the principal issue here, this p affidavit will . focus on the safety margin which stems from
- . consideration of seismic' design."
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l Applicants' fallacious premise), it wou'- also allow them to be able to g
ignore the numerous problems encountered in the hydrostatic and hot
[ ffunctional tests; and retesting would not even be necessary.
i .
_ See also pages 14 and 14a of CASE's 8/29/84 Partial Answer to Applicants' Statement. of Material Facts As to Which There Is No Cenuine Issue Regarding-Applicants'.Use of Generic Stiffnesses Instead of Actual Stiffnesses in Piping Analysis.
i
=l
. MESSRS. WALSH AND D0YLE:
- 7. Applicants state:
"The minimum safety factor conservatively quantified for dynamic loads
. other than those resulting from a seismic event is on the order of 5.0 (Id. at 41) and includes the specific factors noted in item 2e, f, i, j, k, 1 and m, above. If. This safety factor does not includa margins inherent in the computation of dynamic loads. Id."
See answer 2 preceding.
- 8. Applicants state:
"The minimum safety f actor conservatively quantified for static loads is . l.68 (Id,. at 41) and includes the specific factors noted in items 2k and 1, above. Id,. "
See answer 2 preceding.
MR. WALSH:
Also, neither of us has had time even to scan the transcript of the 8/6/84 Applicants /NRC Staff / CASE telephone conference call (Mr. Doyle was 21 L' _ _ _ _ _ _ _ _ _ _ _ _
fx .s
..t 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),'~ehd offcourse, 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 faubstantive) 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 would like to be able to supplement my testimony af ter I have had a chance to review the referenced transcripts, changed Affidavits, and additional documents.
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 Memorandum to G. Grace from G. M.
Chamberlain,
Subject:
CC-1-028-024-S33R -- see answer 3, page 15 Attachment D 7/4/84 TUCCO Office Memorandum to G. Grace from C. Ray, ;
Subject:
AB-1-238 -- see answer 3, page 15 1 22 L
y --
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 Witnesses. Jack Doyle and Mark Walsh. 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, Revision to Resume of Jack Doyle,.
accepted into evidence at Tr. 7042, and CASE Exhibit 841, Revision to Resume of Mark Walsh, accepted into evidence at Tr. 7278; see also Board's 12/28/83 Memorandun. 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 conply with the Licensing Board's directive to answer only the specific statements made by Applicants.
L 41AL-
'(Signed) Mark Walsh STATE OF TEXAS On this, the .2 7 day of h 4 f 4/ M 1984, personally appeared Mark Walsh, kn'own to me to be tb4 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 "
3 /7 day of h/MudH 1984 d l M @ OfedtsI 6 6ry Public in and for lEhe N' j State of Texas My Commission Expires:
SAMUEL W. NESTOR My Commission Expires 13185 L :1
l The preceding CASE's Answer to Applicants' Statement of Material Facts I
As To Which There Is No Genuine Issue was prepared jointly under the personal direction of the undersigned, CASE Witnesses Jack Doyle and Mark Walsh. We can be contacted through CASE President, Mrs. Juanita Ellis, 1426 i S. Polk, Dallas, Texas 75224, 214/946-9446.
Our qualifications and background are already a part of the record in '
- j. these proceedings. (See CASE Exhibit 842, Revision to Resume of Jack Doyle,
' i accepted into evidence at Tr. 7042, and CASE Exhibit 841, Revision to Resume 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.)
n.
We have read the state =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 Summary Disposition, adequately responded to the issues raised by us; however, we have attempted to co= ply with the Licensing Board's directive to answer only the specific statements =ade by Applicants.
n ,
cAn Si ned) JackDnylf Date: /3 / r g M /8[d STATE OF b o d t b COUNTY OF Yew On this, the M R day of kt,.at,I , 1984, personally appeared Jack J. Doyle, known to =e to bQ 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 ce on the 15-k day of Cn t ,
1984 O v'vwe D. .
Notary Public in and for thq My Commission Expires:
State of $n wk_N.
.MY COMMISSICN EXFfRES JANUARY 9,1987
I EN9 Contents July 26,1984, Vol. 213 No. 4 ATTACEST A
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pf W 12 Hyatt hearing traces design chain 20 Big plans for capital roads
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/ *7 Jo 14 Beaver s blamed for train wreck 21 Movable bndges to be replaced .
,. - r ) [.'<$V y pf ",. ,.,,. .
15 Moie r. ukes bite the dust 22 New nuke waste plans eyed W 1- .
15 Demoaats downplay unions 22 Waste plants' increase backed by f .. 16 EPA taghtens toxics penmts pnvate cash g'kg*.-,n.,F::%/f 16 Acid enhances sulfur removal in 23 Hydrogen sparks Canadians pollution control works 23 Giant waste firm taps landfdl gas 17 Alaska bridge funds okaved market t .. . - l..... I ,
.17 Interstate funding lapse'tries 24 Toxics cleanup batde ends
- x ( states' ingenuity 24. Waste to power hospital "b.
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- 26 Yangue engineers aim high (Coter) I s .- -
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.: . 30 Prototype pnson proving itself
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..-( pi g,4. . ' . '. ;, _.- 58 Safety rules remain in government abyss 26 Pragm .usm (Coter) 58 Panels cut state's A E suits 59 Kickback ruled deductible
, 59 Court eases boycott rules -
59 Electncal fums charged with rigging bids Constnaction Economics 46 Materials Prices-brick, time, plaster, metal sheets and roofing
. . 50 Unit Prices-Close race for I-680 project 53 Market Trends-cost indexes, new plans, bidding volume Dopertments
-. 5 Construction Week d
7 Washington Observer l 9 To Fill You In 46 Pulse-bids, plans, contracts ,
12 Precedent
._ Essiertete RJ, ( '. .: . Megaproject on the Yangtze 4-4 J'
, g5i;-y g3' j[..I'TI.f. T ] 64 p,. ,, Senous offense Unusual threats call for diligence g
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' EN=1 Construction Week Granite slipping from Pittsburgh tower- Contractors' cash flow slows--
ne 13-year-old Pittsburgh National Bank Building may After experiencing fewer problems with bill collection need to have its entire granite skin resecured at a cost of as throughout most of 1983, contractors' cash flow slowed much as $5 million. hiany of the stainless-steel fasteners slightly during the first three months of this year, the latest securing more than 4,000 slabs to the outside of the 30- period for which figures arr available from TRW, Inc.,
story building, on one of the city's busiest corners, have Cleveland. Conu ictors in six of seven categories expen-loosened. A problem was first noticed last fall. Now, from enced a drop in the pertentage 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 resecured to prevent "a possible catastronhe," says a bank showing a slight gain. Still, those subs collected only 10.8%
ollicial. He repairs could take as long as 2 years. of their bills on time, the lowest of all construction catego-ries. Of the others, general contractors reported the highest
.Three Mile Island clean'up-- share -of current accounts, 87.6%, .and heating and air conditioning companies the lowest, 52.69 Workers were set to lift the head of General Public IJtility's damaged Eree hiile Island unit-two reactor this week. He Iraqi-Saudi pipe I!nk to be bid next month--
hft is the next major step desised by cleanup manager .
Bechtel Power Corp., San Francisco, on die road to defuel- Iraq has imited bids on consuuction of a 400-mile aude-oil ing the reactor in July,1985. He 156-ton head was to be pipeline to run from its southern oil fields to Saudi Arabian lifted from the vessel and moved to a shicided storage oil lines. Bids are expected by August 11. Consuuction is to stand. A hollow metal cylinder was to h.we been placed on begin in September. Cost is estimated at $500 million to Si top of the vessel for shielding. De cylinder s,ill be filled billion. Basic pipeline design has 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-billion second ne underlying plenum is set for remosal in the spnng. phase of work will continue through Saudi Arabia.
1 LILCO struggling with bankers for cash-- ~ Pressurized pipeline studies-- -
I ne long Island Ughting Company, Mner b N.Y.. strug- Battelle hiemorial Institute's laboratory at Columbus, Ohio, gling to avoid bankruptcy, is tning to c e a consor- plans a multiclient study of stresses induced in existing
. tsum of U.S. and European banks to n .ut he ampany pressurized oil and gas pipelines when new roads are built
. $200 million in credit using accounts receisaW .md stored over them. He institute's researchers believe that present oil as collateral, ne utility's long battle ir <nmplete its design guidelines are overly conservative, leading operators
$3.6-billion Shoreham nuclear plant has lett it deep in debt. to undenake the unnecessarily costly measures oflowering ne $200 million could keep LILCO goimr urad the end of a pipeline, installing casing or replacing the pipe. The
' 1985 if the New York State Public Senice Cummission also institute is secung $10,350 in financial backing from inter.
' ested companies.
agrees to a $281-million rate increase.
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- i Hyatt hearing traces design chaira 1 During tense cross-examina. t ion last International, Inc., St.12)uis; its presi- could lose their licenses to practice in g,
week, the steel fabricator for the Kansas dent, Jack D. Gdlum; and vice president 5fissoun, have their licenses temporarily City Ilyatt Regency hotel said the con- Daniel Al. Duncan with gross negli- suspended or be reprimanded. , Iou 3g nection believed to be responsible for gence, incompetence and unprofession- I2)er after layer of detaded tesumony , 33 the hoters walkway collapse was the al conduct (ENR 2/9 p.14). has urfolded to expose conflicting views
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Engineer Galum (seated left) confers with lawyers about beanngs to determrie fate of tus license. Duncan was GCE's prelect engneer for hotet g
only steel to-steel connection in the of the events surrounding the construe. !
budding that his finn and its subcon- rod
N . tion of the walkwas. He walkways, di-tractor did not design. lie maintained that the critical connection had already been designed by the engineering firm
[ rectly above one another at the hotel's second and fourth floor levels, were [R
's ,
/ - supported by welded steel box beams. c;,;
hired to design the hoters structure. , . ne beams were suspended from the The test: mony came at a heanng m go g cc m eno, , . ceihng by 1 %-m. steel rods and were St.122uis that could determine the fu-t ture careen of the suuctural engmeers involved. It started almost exactly three ec.certe e u m o'c" y attached 'to the building structure at ei-ther end. *[
p "'
In an investigation of the collapse, the years after two pedestnan bridges cross- National Bureau of Standards found C mg the hoters atrium fell, killing i14 3,"g persons and injuring over 200 others.
/ that a connection design change, in
/ l which continuous support rods were re- that I g' l Lis " battle of the experts," as one / placed wah pairs of offset rods, was a l lawyer called it, cou' I set a precedent /, crincal factor m causing the failure. If defming the responsibility implied bv a '
i the ongmal design had been retained. ""f situctural engineer's seal. He hearin the coimection could have supported O l may also unrasel the tangled chain oh Two rode supponeo was.s o awet aes,gn, the weight of the walkwass and the peo-responsibility for the liptt walkway pie on them at the time of the collapse, Duf failure. day Nas said (ENR 3/4/82 p. I th ne petitioner in the case before the Gillum was chief engineer for the de- Gritted. William G. Richev of steel C "'
hiissouri Administratise ficaring Com- sign of the liyatt, and Duncan was proj- fabricator and erector flasens', Steel Co., "
mission is the 5fissouri Board for Archi- ett engineer. If the charges are uphefd Kansas City, Sto., was gnlled bv defense """
tects. Professional Engineers and Land by the state admimstrauve law judge, attorrevs and the judge himself. Richev 3' Sunesors. ne board has charged GCE James B. Deutsch, the two engmeers admitted that whde the flyatt was in t2 Ew.My 26 tw Q]
- M design. Ilavens had too ruuch work. one. rod system and the difficulty of sponsibility found in contract docu-De firm sent partly completed shop buying single rods 46 ft long. ments. Plaintiff attorneys cited drawings to a subcontractor, steel detail. Defense attomey Lawrence B. Grebel documents mentioning the Aisc Code er WRw Engineering, Kansas City, Sto., presented documents showing that in of Standard Practice
- " Approval [by the for completion. Richey said llavens 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 atrium, 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 er's staff cakulated loads and sized make up the 46-ft length needed in the designed by the fabricator.,,connecuons members. Gillum and Duncan say they single. rod design. Defense attorn , on the other hand, I never knew of WRW's involvement. The buck stops. A key issue in the- cited general conTrions in the specifica-
,.'" Richey maintained that ccE designed case is the responsibility implied by a tions such as: " Approval does not re-
' '";Y the cr;ucal walkway connection. "Are structural engineer's seal. "According to lieve the contractor of responsibility for you trymg to tell this court that the one Stissouri statute, ultimate responsibdity errors or omissions." . -
and only steel-to-steel connection that tests with the structural engineer, no , Judge Deutsch observed, "There are
- "Y was totally designed (by the structural matter what," said Patrick hicbrney, at- disclauners of responsibility that let any.
engineer] was the box. beam-to-hanger- torney for the licensing board. AlcLar-. body blame everybody che."
' second chance. Considerable testi-I2, ' . .... . , s
)w l. mony concerned a collapse of part of I.
I. , g l hO ?. +1.',. a : ks, :14 '."$,
- 3. ,rD.'J the flyatt atrium's roof dunng construc.
g.- Y .. f ~" ~; , - tion-an accident in which no one was 4.- .
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%. brid es and found them to be satisfac.
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$ tory.g' ne construction manager's notes j ,, , [/ . - .- of a meeting after.the atnum collapse
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also say: " Jack Gillum confumed 6.n
. ^: Iv3 . .every
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_; O' connection in the atrium, bcs l 'i g JJ ,
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@WW steel to-steel and steel.to-concrete, had 1 V ,,, 4 . M 4' y ~?.
4.
[@f: %;W.. - d been reviewed." .
ne heanng was originally slated te
< / m.2 run two weeks, but it now seems that it do, s - > . . . - 3,lJMM..,w g , .v
-. r' . ,..
Weae, . A -2 % may be recessed untd mid-August and tusastrous mi may kaed 114 persons and ryured over 200 oters at enoon tea dance. coritinued then. The judge's decision is not expected until the fall. m
- [, rod connection?" defense asked,If there attor-were ney cited the statuac. 'Any registered ney Reeder R. Fox. engmeer who ahixes ,im u ature and Sabota9e to delay others, I'm not aware ofit." said Richey. personal seal to anv sucn p ns...shall Opening Of Pipeline
- Richey was also questioned on a cru- be personally and protesuonally respon.
t cial phone call that he claims he made sible therefor."
".e"he v re to Duncan at ccr to clear up a discrep. A plaintiff :xpen vr. ness, Richard F.
ancy in a structural drawiryg. In that Fer uson, a retired engineer who ral-gas pipeline m Alaska will cost the Apparent sabotage of a 100-mile, natu.
drawing, one view of the second and hel write the American Institute of owner about $400,000 to repair holes g founh-level walkways shows a single, Ste I Con truc:ien (.usc) specifications and check for others. But the anticipat-
""j continuous rod supporting both. But a for structural steel design, said the engi- ed fall opening of the newly installed
- detail on the same dramng indicates neer of record usuall> has to delegate line . val only be delayed by 15 to 18 that a rod should terminate under both his duties because there's too much days.
the second and fourth-Ictel walkways, work. "But he cannot delegate his re- seven holes were found recently in a
, as}
implying a double. rod design. sponsibility... .Dere has to be a point 6-mile section of pipeline near Eagle "ed Rdhey says, "He indicated to me to where the buck stops." River when water tests ,showed lost "y make it two rods. Iinformed WRW what The defense mamtains, on the other pressure in the lower portion of the Duncan informed me to do." hand, that it is the " custom and practice pipe. Work crews dug up at section of ' ~
P$e' Duncan issued a press release on the in the construction industiv" for the the %-in. thick pipe buned !! ft be.
day of this testimony denving that this steel fabricator's engineers ' to design neath a creek that flows into Eagle conversation ever took place. Defense connections. In that way, fabricator- and found % in to 3/16.in.-dia boles Rher
$;g -
attomeys, using Havens purchasing doc- crectors can choose details that suit the dnlled through it. Sabotage is also?sgs -
uments and ' speed memos" as en- equipment in their shop and the experi. pected on a sundar line in western Mnn.
f', dence, maintain that the change to two ence of their workers. : tana (ENR 7/19 p.' 16). M. 4 d rods was a result of liasens' and WRW's Discialmers. Both sides trade.1 para.
concems about the.contructibility of the. graphs of boilerplate language on tre- star Natural Gas Co.,-Anchorage, a sub-Spokesman Daniel Dictigraeff, of En.
ENR/.A4y26 f984 13 Y . .
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k, UNITED STATES
' NvCLEAR REGULATORY COMMISSION
, , g.
, : f r.y g a ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
_P g WASHINGTON, D. C. 20555
\led 1v /
~ *****
Ma'rcn.ll, 1983
- ATTACE C T B ,
MEMO ~FOR: - D. Okrent
~ACRS Members FROM:. M.-Sender, SU8h CT: SUGGESTIONS.FOR THE LETTER ON ACCIDENT PRECURSOR STUDIES (APS)
As noted in the Reactor Safety Study Review Committee Report, the examination of accident precursors can provide very useful safety information. Tney can
.s bow: -
- 1. where improved maintenance practices are needed (e.g. , tne Salem circuit breakers).
- 2. whether there are adequate diagnostic capaoilities to indicate impending t
problems and now to control tnem,
- 3. wnetner plant operating procedures are adequate and effective.
4 deficiencies in engineering design, construction and application of plant systems , controls , and components ,
S. tne stage at whicn accident consequences can be controlled most effectively.
- 6. effects of plant aging on safety,
- 7. quality deficiencies that 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 nas been directed to the implications of accident precursors in probabilistic risk assessment. Tne results of tne Oak 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. So mucn subjec-tive judgment'is involved in tne probability evaluation tnat tne 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 scrve tne needs of 'otner aforementioned purposes. Other screening criteria should be sougnt.
J. fn'- /
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4 f' X Okrent/ACRS Members . Maren 11,1983 t-.
~
~Tne' study- ef fort snould include entire cnains of' events for' important pre-:
cursors. = For example, tne Browns Ferry fire event 'snould include tne-frequency of fires . initiated at tne barrier penetration ' seals and tne
~THI-2 event ~snould include contricution of the THI-demineralizer resin
- ~
. . _ problems to the accident sequence and the system interactions from tne instrument air system that initially upset the turbine condenser controls.
Such studies ~ need careful review but'little purpose is served by using tne ,
original WASH-1400 ~ participants as reviewers. Ineir objectivity is certain to be cnallenged. Tne INPO ~ review was obviously-di rected to refuting tne Oak, Ridge study 's probability juogments. Tne lack of-a qualifiec statistician to assist in ' evaluating the use of statistical data makes tne value of tnese reports questionable. Tne industry groups sucn as INP0 or individual utility
. groups are best able to perform the APS work. But tne groups should include a good selection of system and equipment specialists as well as statistical and probaoility analysts.
This activity again points up tne problem of using "PRA" type studies -as tne basis for public safety assessment. In tnis case it has led to con- ,
siderable wasted effort to explain numerical values. It did not pnysically ennance plant safety.
cc:
R. Major, ACRS R. Fraley, ACRS M. Libarkin, ACRS J. C. McKinley, ACRS 1
1 1
-l Page Revised: 3/14/83
y _.
' . . igg c: -61 ATTACILI C -
TEXAS L'TILITES GENERATING COMPANT V
j July 4, 1984 Orr!CE MEMoa ANDUM T. G._ Grace - - = cien rto... Team. _ _
subini. CC-1-028-024-533R' -
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j
.' From the' attached STRUDL analysis without the skewed bolt at' joint 10, the bol}. interaction for joint 12 is the following:
' x- Fo rce = 96 8 y- Fo rce = 47 47 8 z- Force = 6471 W 2
gg 4747
+/6567d g) = 0.353 e 1 (ok)
The bolt interaction for joint 14 is the following:
x - Fo rc e = 214 =
y- Fo rc e = 9740 s z- Force = 6362 2
9740 6365 gg +g = 1.30*
- In this case a 30' overstress of 'the bolt does not mean failure but only a reduced factor of safety'. In this case it is an absolute worst case condition be-cause we are assuming no forces are being resisted by the canted bolt. In actuality the tremendous ductibility of the A36 rod at joint 10 woulc re;?st some of the load and reduce the interaction at joint 14 Very Truly Yours, f/f ) s G.4. Chamberlain-GMC/jrf CYG( ~7.u~s ' --- --- - _
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00'J:ETE' UNITED STATES OF AMERICA U%RC NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LIdMi1dEBdRDN0:41 In the Matter of }{ ,, u ,
}{ O.g ; is y W g TEXAS UTILITIES ELECTRIC }{ Docket NosN5'0-445-0 L.,
COMPANY, et d . }{ and 50-446 O L (Comanche Peak Steam Electric }{
Station, Units 1 and 2) }{
CERTIFICATE OF SERVICE By my signature below I that true and correct copies of CASE's Partial Answers to Applica, ts,hereby n certifyMotions for Sunmary Disposition RegaNing: Consideration of Local Displacements and Stresses; Differential Displacement of Large-Framed, Wall-to-Wall and Floor-to-Ceiiing ripe supporcs- Consioeration or rorce vistrioution in Axiai Rescraints, Upper Lateral Restraint Beam; Use of Generic Stiffnesses Instead of Actual Stiffnesses in Piping Analysis; ano darety ractors have been sent to the names listed below this 28th day of August ,1984_,
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 Bethesda, Maryland 20814 Director U. S. Nuclear Regulatory
- Dr. Kenneth A. McCollos, Dean Commission 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 i
Oak Ridge, Tennessee 37830 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 l
1 l
l
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f' Js ,
.w.
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 Commission 611 Ryan Plaza Dr., Suite 1000 Arlington, Texas 76011 Lanny A. Sinkin 114 W. 7th, Suite 220 Austin, Texaa 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
_P
~
- m #2
,{Mrs.) Juanita Ellis, President CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 2