ML17139B111
| ML17139B111 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 09/24/1982 |
| From: | Persh R Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8210180274 | |
| Download: ML17139B111 (14) | |
Text
A 4
SEP 2 41982 Docket Wo.:
50-387 APPLICAWT:
Pennsylvania Power
& Light, Company FACILITY:
Susquehanna Steam Electric Station, Unit 1
SUBJECT:
SUNIARY OF SEPTEffBER 9, 1982 flEETING OW TllE SUS(UEHAWWA It<DEPENDENT DESIGW REVIEW On September 9, 1982, representatives of Pennsylvania Power 5 Light Company (PP&L)
- Bechtel, and Teledyne Engineering Services (TES) met with members of the WRC staff to discuss the conclusion of the final report issued by TES on their review of the feedwater system inside containment at Susquehanna, Unit 1.
A list of attendees is provided as Enclosure 1.
PP&L responses to the TES review is provided as Enclosure 2.
The conclusions reached in the final report indicated that TES was concerned with two areas that do not allow extrapolation of the conclusions to the total plant design and gA process.
These two areas are (1) reconciliation of as-built conditions and (2) design specification requirements.
The TES re'view of the Bechtel responses to the above two concerns indicated that there is no impact on the safety for the feedwater system.
The staff was concerned about the two areas identified in the TES final report and expressed to PP&L that the design review should be extended to focus on the acceptability of the as-built reconciliation process for safety-related systems other than the feedwater system.
PP8L committed to perform the supplemental work in a letter to the HRC staff dated September 16, 1982.
Teledyne will provide an addendum to their final report by Wovember 1, 1982.
Enclosures:
As stated Robert L. Perch, Project blanager Licensing Branch Wo.
1 Division of Licensing cc w/encls.:
See next page 8210180274 820924 PDR ADOCK 05000387 P...
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OFFICIAL RECORD COPY USOPO: 1981~5-960
y Susquehanha I:;r. Ho rma n M. Curt i s Vice President Engineering and Construction Pennsyl vania Power 8 Light Company Allentown, Pennsyl vania 18101 SEP 2 4 1982 ccs:
Jay Silberg, Esquire Shaw, Pittrr!an, Potts 8 Trowbridge 1800 l1 Street, M. M.
Mashington, D. C. 20036 Edward l1. Iiagel, Esquire General Counsel and Secretary Pennsylvania Power 5 Light Company 2 I!orth liinth Street,!
Allentown, Pennsyl vania 18101 Nr. Milliam E. Barberich Muclear Licensing Grip Supervisor Pennsyl vania Power 8 Light Company 2
Horth lii nth S tree t Allentown, Pennsyl vani a 18101 Nr. G.
Rhodes Resident Inspector P. 0.
Box 52 Shickshinny, Pennsyl vani a 18655 Gerald R. Schultz, Esquire Susquehanna Environmental Advocates P. 0.
Box 1560 Milkes-Barre, Pennsyl vania 18703 I'!r. E. B. Poser P roject.
E ngi neer Bechtel Power Corporation P. 0.
Box 3965 San Franci sco, Cali forni a 94119 Dr. Judith H. Johnsrud Co-Director Environmental Coalition on tluclear Power 433 Orlando Avenue State Col lege; Pennsyl vania 16801 li!r. Thomas N. Gerusky, Director Bureau of Radiation Protection Resources Commonwealth of Pennsyl vani a P. 0.
Box 2063 Harrisburg, Pennsylvania 17120 Ns. Colleen.Aarsh P. 0.
Box 538A, RD 84 N!ountain Top, Pennsyl vania 18707 Nr. Thomas J. Halligan Correspondent.
The Citizens Against Nuclear Dangers.
P.. 0.
Box 5
- Scranton, Pennsyl vania 18501 Nr. J.
M. Nillard Project Nanager Nail Cod 395 General Electric Company 175 Curtner Avenue San Jose, California 95125 Robert M. Adl e r, E squi re Office of Attorney General 505 Executive House P. 0.
Box 2357 Harrisburg, Pennsylvania 17120 Nr, R,
Haynes, Administration U, S.
Nuclear Regulatory Commission-Region I 631 Park Avenue
'King of Prussia, Pennsylvania 19405
ENCLOSURE 1
List of Attendees NRC T. N. Novak B. J.
Youngblood R. Bosnak R. Perch D. Terao H. Bramer Bechtel H. Hollingshaus R. Parekh N. Khlafallah R. Shovlin T. Crimmins W. Rhoads D. Satter W. Barberich Nutech G. Sanders TES D. Landers
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ENCLOSURE 2
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Teled nes Inde endent Review Res onse to Findin No.
1 This is not really a finding but.a difference in opinion on=interpretation and intent of ASME Code, Subparagraph NB-3113.3.
Teledyne considers "Loss of H0 pumps, MSIV closed" asan upset condition.
Teledyne references NB 3113. 3 which states that "The total number of postulated occurrences
... shall not cause more than 25 stress cycles having an Sa value greater than that for 10 cycles from the appropriate fatigue design curves...".
Teledyne believes that the incident results in 8 stress cycles per event-resulting 80 stress cycles (10 events).
It is Bechtel's position that the loss of F.
W. pumps, the MSIV closed, is an emergency condition.
This is consistent with GE supplied documents drawing No.
- 761E579, 158B8369 and Spec.
22A2925.
It should be noted that under this condition, only 10 events are postulated to occur per GE's documents.
In older documents (plants) this No. of events was only 5.
This classification is justified because an emergency condition is categorized by the frequency of events and not by the No. of stress cycles associated with such an event.
If the latter was to be the case, for a given condition that may have more than 25 cycles, the same condition would be classified differently form one system to another depending on the amplitude of the stress cycles.
This would also be an inconsistent approach which would require performance of a stress calculation before a condition can be classified as an emergency or upset.
Bechtel does not interpret paragraph NB-3113.3 to require that an emergency event must be classified as an upset event if more than 25 stress cycles having a stress amplitude greater than the endurance limit. -Bechtel's stress 'reports were prepared based on the interpretation of Section III code given as follows:
o No evaluation of secondary type loads associated with emergency conditions are required.
Reference Para.
NB3224.5 and figure NB-3224-1 of the code'.
i. Fatigue evaluation of secondary type loads for znergency condition is not required.
Reference Paragraph NB-3655.
o The requirement of maintaining Sa to below endurance limit for stress cycles greater than 25 applies to primary type loads only.
Under this interpretation, the primary stress associated with loss of F.
W. pumps with the MSIV closed, are below the Sa value.
In order to respond to Teledyne's position, PP&L requested a study calculation in which Bechtel recalculated the fatigue life of the feedwater system considering all stress cycles associated with the emergency condition (the loss of FW pumps, MSIV closed) for three most critical components.
The results of this study shows insignificant change in the cumulative usage factor values documented in the stress report.
A survey of this emergency condition for all other Class 1 piping system was also performed.
Bechtel has found that the same emergency condition for all.other systems is much
less severe than that for the Feedwater system.
As the thermal'ransients due to this emergency condition for the Feedwater system have only insignificant impact on the cumulative usage factors, the impact of including the emergency condition in fatigue calculation for other systems will be negligible.
Our conclusion is that potential fatigue damage associated with the emergency condition<cycles is insignificant.
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Teled ne's Independent.
Review Res onse to Observation No.
1 Teledyne states that the Spec. refers to 33 other documents which provide require-ments necessary to satisfy the Code.
There is no indication that certifier of Design Specification has any control over these other documents and, therefore, can not determine their acceptability with respect to his certification.
These documents do not list appropriate revisions and/or dates.
Bechtel does not include the. revision number of the referenced documents in the design specification because the latest revision of the referenced document always applies to the piping system.
The latest revision and date of issue of the docu-ments (Specifications and Drawings) are indicated on the Drawing Control and Specification Register.
- However, due to an ASME audit finding the project instituted the following additonal efforts in the certification of the Design Specifications:
l) Design Specifications have new certification statement,
- 2) Design Specifications may be certified by a Registered Professional Engineer from any state,
- 3) Referenced documents shall be certified by Registered Professional Engineer.
Since the reference documents are certified and the latest xevision is applicable and can be obtained or determined through the Document Control, we consider the observation is satisfactorily resolved.
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~o Teled e's Inde endent Review Res onse to Observation No.
2 Teledyne states that no information in the form of design drawings, procedures, instructions, etc.,
were evident which demonstrate bolt tightening of special pipe clamps is a requirement.
Bechtel has stated 'that pipe clamps on large bore.piping, including the special clamps on the feedwater line,.do not have specific torque requirements.
Field installation procedures dictate that the bolts only be wrench tightened.
This procedure along with subsequent QC inspections ensure clamp to pipe contact.
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o Teled ne's Inde endent Review Res onse to Observation No.
3 Teledyne states that branch connections which are located in close proximity to the PPV (the flow mixing zone) may not have been conservatively addressed by Bechtel in other'iping systems.
Bechtel has stated that branch
'onnections located within ten diameters (10D) of the RPV are qualified using thermal transient temperatures associated with the RPV.
In those cases where this approach is too conservative, the temperature at the connection is calculated using dead leg thermal conduction equations discussed in all Class 1 Stress Reports.
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MEETING
SUMMARY
~e SEP 2 4 1982 ZDocument Control (50-..387) >
NRC PDR L PDR TERA HSIC LB¹2 Rdg.
MRushbrook Project Manager R. Perch
- Attorney, OELD OIE Regional Administrator; Region PARTICIPANTS HRC T. M. Novak B. J.
Youngblood R, Bosnak
. R. Perch D. Terao H. Brammer