ML17159A262
| ML17159A262 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 04/14/1998 |
| From: | Nerses V NRC (Affiliation Not Assigned) |
| To: | NRC (Affiliation Not Assigned) |
| References | |
| TAC-MA1014, TAC-MA1015, NUDOCS 9804170081 | |
| Download: ML17159A262 (19) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 14, 1998 MEMORANDUMTO: Docket File FROM:
SUBJECT:
Victor Nerses, Senior Project M ag r Project Directorate 1-2 Division of Reactor Proje
- I/
Office of Nuclear Reactor Regulation SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND2-DOCUMENTATIONOF ADVANCEINFORMATIONON NRC REGULATEDACTIVITIES(TAC MA1014 AND MA1015)
The attached draft document, transmitted by facsimile from Pennsylvania Power and Light Company, provides the staff advance information on NRC regulated activities.
Docket Nos. 50-387/50-388 DS B
Docket File PUBLIC RCapra 9804i7008i 9804i4 PDR ADOCK 05000387 P
I t
I gi r
'L E
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2 Robe@ O. Syrern Senior Vice PreaMent Generetton end Chiet Nuclear OScer Tet. 810.774.7502 Fa(810.774.5019 E~: rbbyramepapl.corn PPLL, inc.
Two North Ninth Street Atbrdawn, PA 18101-1179 Tel. 810.774.5151 httpJhow.pepl,contt U. S. Nuclear Regulatory Commission Attn..'Document Control Desk Mail Stop P 1-137 Washington, D. C.
20555 OVAL SUSQUEHANNA STEAMELE WITHDRANALOF EXPEDITED RE OF TECHNICALSPECIFICATIONS/BASES 3/4.3.7.11 AND3/4.11.2.6 PURSUANT TO ITS AND RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION-OFFGAS SYSTEM MODIFICATIONS P A4882 FILER41-2 Docket Nos. SO-387 and 50-388
Reference:
R,G. Byram to USNRC, "&pedtted Revletv/Approval ofTechnical Spectflca+on Sections/Bases 3/'4.3. 7 11 and 3/4.11.2.6Pursuant to ITS, " dated March 27, 1997; R G. Byram to USMC, "Proposed AmendmentNo. 205 to License NPF-14 and Proposed Amendment No. 170 to License>PF-22: Main Steam Line Radiation MonitorSetpotnt Change and Change to Ra foactive Gaseous Effluen Monitoring System, "datedMarch 16, 1998.
3)
USNRC to R G. Byram, "Oggas System Modifications, Susquehanna Steam Flectric Stat/on (SSES). Units 1 and 2, dated March 20, 1998.
The purpose ofthis letter is to withdraw the PP&L, Inc. (PP &L)request that NRC expedite the review and approval oftwo Technical Specification sections ofthe proposed ITS amendment
{reference 1), and also to respond to the NRC's Request for Additional Information related to offgas system modifications (reference 3).
PP&L requests that the expedited review submittal (reference 1) be withdrawn from consideration because it has been superseded by the Technical Specification proposed amendment change identified by reference 2.
The attachment to this letter provides the PP&L response to the NRC Request for Additional Mormation (reference 3) related to the offgas system'modifications.
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3 PILE R41-2 PLAN&82 Document Control Desk Ifyou have any questions please contact Mr. J. M. Kenny at 535.
Sincerely, R. G. Byram Attachment copy:
NRC Region I Mr. K, M. Jenlson, NRC Resident Inspector Mr. V. Nerses, NRC Sr. Project Manager
'l bc:
D. L M. S.
A. P.
G. T.
J.
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R. D.
Pilchner Gorski Iorfida Jones Kenny.
Kic}dine GENA63 GENA12 NVCPT NUCSA4 GBNA61 GFXA61 G. D. Miller R. A. Saccone M. W. Simpson Nuclear Records Licensing Piles GBNA62 GENA12 GENA63 GENA62 GENA61 RDK:rdk~
48S2,RDK 04I09/9S t;41 PM
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4 ArlACHMENTTO PLAR882 Page 1 of 10 Response to Request forAd 'ormation OITgas System Modifi ti Back round Removal of the Offgas Isolation on High Hydrogen 'concentration is required to support the implementation ofHydrogen Water Chemistry (HWC). Implementation of this modification under 10CPR50.59 is contingent upon NRC approval proposed amendment no. 205 to license NPF-14 and proposed amendment no. 170 to license NPP-22 submitted on March 16, 1998.
This change in part will movelrelocate the Main Condenser Offgas Treatment System Explosive Gas Monitoring System and Radioactive Eftluents Explosive Gas Mixture to TS Section 6.0, FSAR Section 16.3 (Technical Requirements Manual) and controlling documents.
This modification is needed to avoid an offgas isolation following a loss of oxygen injection.
Under HWC, hydrogen gas is injected into the reactor vessel with feedwater.
This reduces the radiolysis ofwater to hydrogen and oxygen by up to 90%.
As a result, oxygen must be injected upstream ofthe recombiners to react with the hydrogen injected to feedwater.
A loss of oxygen injection would cause hydrogen injection to shutdown, but would result in a high hydrogen transient downstream ofthe recombiner, until residual hydrogen in the steam cycle had been purged.
With the current design, offgas would isolate and potentially cause a plant
'hutdown on loss ofcondenser vacuum.
This modification willpermit hydrogen to be passed through the offgas treatment system, to be diluted to well below the lower flammability limit by the turbine building vent flow.
As presently
- designed, the Offgas system will automatically isolate itself from the main
. condenser by closing the Mgas inlet valves to'he first stage Steam Jet AirEjectors (SJAB) when the hydrogen analyzers on the recombiner condenser outlet detect >2% hydrogen by volume (Hi-Ht hydrogen setpoint).
This is intended to preclude the formation ofexplosive gas mixtures in the downstream offgas treatment system.
The setpoint is half of the lower flammability limit for hydrogen in air (4%), which is also the Susquehanna Technical Specification limit PS LCO 3,1 1.2.6).
This design is one acceptable approach to eliminating the potential for release of activity to the environment as a consequence ofa hydrogen explosion in the offgas treatment system.
The other acceptable approach is to design the system to contain a hydrogen explosion.
PP8cL is committed to Branch Technical Position (BTP) ETSB No.
11-1 (Rev.
- 0) "Design Guidance for Radioactive Waste Management Systems Installed in Light-Water-Cooled Nuclear Power Reactor Plants."
This BTP did not address requirements for explosive mixtures in gaseous radioactive waste systems, Subsequently, the BTP was superseded by Regulatory Guide (RG) 1.143, This RG was revised in October of 1979 to address this concern.
KG 1.143 Rev.
1 Section 2 "Gaseous Radwaste Systems" states "Ifthe potential for an explosive mixture of
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5 ATTACHMENTTO PLA-4882 Pa of 10 hydrogen and oxygen exists, adequate provisions should be made t e buildup of explosive mixtures, or the system should be designed to withstand he ects of an explosion".
To confirm whether or not the Susquehanna SES (SSES) offgas systems are hydrogen "detonation proof', General Electric (GE) has completed an evaluation titled "Evaluation of Susquehanna Offgas System Pressure Integrity for Hydrogen Detonation" (EC-072-1007).
In
- summary, GE's analysis of the Susquehanna offgas system showed by calculation that the pressure
- boundary, consisting of piping and major components, is either capable of withstanding multiple hydrogen detonations or the system is designed to preclude the existence ofa detonable gas mixture. PP&1. has reviewed and concurs with GE's evaluation.
Therefore, automatic isolation is not necessary to preclude explosive gas mixtures.
Existing capabilities for hydrogen monitoring will be retained.
Operating procedures willbe modified using GE SIL 150 to provide guidance for responding to high hydrogen alarms.
Additionally, appropriate revisions willbe made to the PSAR and other controlled documents.
Responses Queflon 8l Ae method of calculation ln ECW72-1007 was based on GE report, PEDF11146 with some modijicat/ons ln determlnatlon of detonation peak pressure.
En lt/EDE-lll46, the detonation peak pressure /s afunction ofthe length to diameter ratio (VD).
ForVD <<'7, the peakpressures are 17 times the /nitialpressure.
ForVD> 7, the peak pressures are 170 times the initialpressure.
EC072-1007 uses 80 times the /nitialpressure as the peak pressure for an 8-/nch diameter piping with IJD > 7in the SEES oggas system Alsfactor of80 Is not supported byNEDE-11146 method.
lee licensee indicated that the factor of170 was developed based on the measurements In small diameter piping of S inches or less and that for piping diameters of 8-Inches and larger, both theory and measurements support a factor oftwo consenatlsm In the small bore piping data.
The licensee further rejerred to the actual measurement ofa long 24-inch diameter piping to support /ts argument.
The staghas rev/ewed the l/censee's justigcations and has thefollowingquest/ons:
(a) &pia/n why the measurement data from 24-inch diameter piping are more applicable than the data Pom inchfor the application of8-/nch piping.
/b) Fhrthermore, the peak pressure is a function of(VD), not just a function ofpiping diameter p)).
Erpla/n why the licensee adjusted thefactorfrom 170 to 80 based on the piping diameter alone7
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(c) fee licensee is required to provide applicable supporting docume regarding the factor oftwo conserwttsm for the steato review rhe r licensee should ttse the method inhKDElll46 without madigcations.
easurements and theory Otherwise, the Res onseto uestlonPI.
a b
The design method of NEDE-11146 was modified by GE for the SSES evaluation to remove excessive design conservatisms known to exist in the original methods developed by GE.
The strict application of the NEDE-11146 methods, while cost effective for new construction, would result in excessive overdesign and unnecessary expense ifapplied to an existing system, For this reason, GE researched existing data and theory regarding peak pressures developed in piping larger than S-inches, which formed the basis for the peak pressure ratio of 170 used in NEDE-11146 for all piping diameters.
Reference 3 ofcalculation EC472-1007 showed a rmCimum pressure ratio ofapproximately 80 for 24-inch piping. The data for 24-inch piping clearly supports the existence oflower pressure ratios in large diameter piping, but the data does not specifically address 8-inch piping.
Therefore existing theory was quanti6ed to achieve pre-detonation run-up as piping diameters increase.
To quantify the relationship between pipe diameter and pre-detonation run-up length (length of reaction zone &om point ofignition or ddlagation initiation to onset offullyturbulent conditions and detonation initiation), the relationship between peak pressure ratio and the ratio of pre-detonation length to piping length for acetylene detonation (Reference 1 ofthis letter) was used.
This relationship for acetylene, which edubits pressure ratios up to about 400, was modified to represent the maximum peak pressure ratio of 170 observed for hydrogen detonation.. Using this relationship and the detonation run-up length for hydrogen of 70 centimeters (Reference 2 of this letter), a relationship between pressure ratio and pipe length to diameter ratio for various piping diameters was developed (Reference Figure 1 of this letter).
Figure 1 is a graphic representation that shows the relationship between detonation pressures and pipe size for various gasses which was developed Rom references 1 and 2 ofthis letter. Therefore, the pressure values forhydrogen detonations cannot be directly compared to the data identified in calculation EC-072-1007.
From this figure it is evident that the effect of pre-detonation cascading for 8-inch piping and larger, which shows a maamum pressure ratio ofabout 60, is very small compared to 4-inch piping.
This same effect is explained in Example 4 of Reference 3 of calculation EC-072-1007, which cites the example of 12-inch piping.
The example states that self-propagating detonations are very dUBcult to establish because "when a small ball of fire forms in a large volume of acetylene, it may not have suaicient available heat to raise the adjacent layer of cold gas to its ignition point." In other words, it is difBcult to form the uniform deflagation tront across the piping cross-section needed to produce the pre-detonation run-up or piston eKect to compress the unburned gas. ahead ofthe flame front. Therefore, based on the above information, the piping analysis for Susquehanna offgas piping 8-inches diameter and larger was based on a pressure ratio of80 (reference 3 ofcalculation EC-072-007 for 24-inch piping) rather than 170.
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7 AVl'ACHMENTTO PLA4882 Page 4 of 10 Res onse u stion ¹i. c Data for the 24-inch pipe pressure ratio of approximately 80 is 'Q Reference 3 of calculation LsC-072-1007.
Development ofpigure 1 ofthis letter is discdAspl the responses to 1 (a) 8r, (b).
Question st2
'I77einitialpressures p'J, usedin Table 1, Summary ofSusquehanna Piping Analysis," appears to be the pressures corresponding to the normal plant operation.
In Final Safety Analysis Report Table 11.34 it shows that the pressures corresponding to startup mode are higher. &plain why the analysis used the lowerpressures.
Res onse to uestfon ¹2 Offgas system normal pressures were used in the calculations because at low power conditions and high air flow rates present during startup, detonable offgas mixtures can not be present.
The footnote to PSAR Table 11.3-8 notes that at startup conditions, negligible hydrogen is present.
At low power conditions hydrogen willnot be injected by the HWC system.
'ection 2.0 ofCalculation EC72-1009 Iruhcates that ANSVAM'S.4-1979 Appendix C provides an acceptable methodfor analyring a hydrogen d'etonatlon In the oggas system.
The summary discussion In Calculation EC472-1007 further implies that the criteria were accepted In Regulatory Guide 1.143.
- However, the discussion in Regulatory Guide 1.143 Indicates that the standard would be endorsed separately.
Please provide Ihefollowinginformation.
a.
A spectffc reference that indicates the procedure spectffed In Appendix C ofANSVANSSS.4-1979 has been previously reviewed and approved by the stag b.
Table l ofRegulatory Guide l.143 hsis the applicable equipment design codes.
Describe how Ihe crlterlafordetermining wall thickness speci/fed in Equahon 2 ofAppendix C ofANSVANSSS.4-1979 met the design code requirements speci/i ed In Regulatory Guide l.143.
Res onse to uestion¹3 a
There is no specific reference that indicates the procedure specified in Appendix C ofANSVANS 55.4-1979 has been accepted by the NRC.
However, NUREG/CR-5973 (Rev 3) identified ANSVANS 55.4-1979 as a document that provides background information.
The basic methodology used in the design of detonation-resistant BWR Oagas systems is described in Appendix C of ANSVANS 55.4-1979.
That methodology, with slight variations between Architect - Engineers and industry equipment supplies has been followed since the early 1970's.
This methodology was used in licensing ofthe Limerick Offgas system design.
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8 ATTACHMENTTO PLA4882 Page5 of 10 nse to uestion h8 FSAR Table 3.2-1 "SSES Design Criteria Sumrmiry", Note 31, has been r d now identifies the design criteria for the Gaseous Radwaste System per ESTB 1l-l Rev. 0., 'sion willbe incorporated into the next update to the FSAR.
The design guidance in Tab egulatory Guide 1.143 is not applicable for detonation analysis purposes.
Appendix C of SVANS 55.4-1979 is the applicable guideline to use for detonation analysis.
Section 2.0 ofCalculation SC<72-I009 indicates that the destgn guidance documents do not require design for a hydrogen detonation simultaneous with a seismic event.
However, ANSVAÃSSS.4-1979, Appendix C contains the following statement:
"14 method assumes the absdnce of simultaneous secondary events such as earthquakes."
Ae statement does not indicate that additional load combinations are not required.
Describe the design load combinations for mechanical equipment and piping that are applicable to the design ofthe oggas system.
Reference the Susquehanna FQR section that contains the load combination criteria.
I nse to uestion N ESTB 11-1 Rev. 0 "Design Guidance for Radioactive Waste Management Systems Installed in Light-Water-Cooled Nuclear Power Plants",Section II.a.(3) states that "for systems that operate near ambient pressure and retain gases on charcoal adsorbers, only the tank elements and the building housing the tanks are included, (e.g. charcoal delay tanks in a BWR)." The SSES ofFgas system charcoal adsorber tank elements and the building housing the tanks are designed to meet the requirements ofESTB 11-1 Rev.0, section V. There are no additional design load combinations for the SSES Oegas system and therefore, no section in the SSES FSAR contains specilc load combination criteria. FSAR Table 3.2-1 "SSES Design Criteria Summary", 'Rote 31, identi6es the design criteria for the Gaseous Radwaste System.
gucstton $$
Calculation EC72-I007 provides a summary ofthe evaluation ofthe oggas piping and equipment using the crlteria tn ANSI/ANS55.4-I979 Appendix C.
She summary indicates thar the analysis demonstrates that material yteld stresses would not be exceeded following a detonation with the Susquehanna oggas system. Provide thefollowinginformation a.
Table I ofCalculation FCA72-I007 lists the yield stress values used in the evaluation.
Provide the
'echnical justification that the reported yield stress values are applicable to the piping at Susquehanna.
b.
Z'able I ofCalculation FC-072-1007 lists the. strain hardening exponents used in the evaluation.
Provide the technicaljustijication that the reported strain hardening exponents are applicable to the pipingat Susquehanna.
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9 ATTACHMENTTO PLA<882 Page 6 of 10 c.
The procedure specified in ANZVANS55.4-1979 Appendir C only applie p
hoop stress due to pressure.
Discuss the potential for addfttonal djwamlc loads resulttng Pam kg" nt pressure wore propogotton through the system os o result of the delononon.
Describe th Pnent ond component support criteria that are applicable to this scenario.
n to uestion¹5 a 4 Yield values and strain hardening exponents for C1010 carbon steel are documented in References 2 and 5 of Calculation EC-072-1007 at temperatures of 70', 400', and 900'.
The yield strength values and strain hardening exponents in Table 1 of Calculation EC-072-1007 for carbon steel (A-106, Gr B) are linearly interpolated at the required temperature.
The yield strength value and strain hardening exponents for stainless steel (SA-312, TP 316 and SA-213, TP 316) is from Reference 4 of calculation, Table 1 "Stress-Strain Properties in Simple Tension" for T-304 stainless steel.
Based on subsequent reviews, the yield strength values and strain hardening exponents have been corrected in Table 1 ofCalculation EC-072-1007 (attached) to reflect the values ofReference 4.
Res onse to uestion¹5 c
'ine Properties k Conditions in Table 1 of Calculation EC-072-1007 lists Po (Operating
- Pressure, psia), P (Peak Internal Detonation Pressure, psia) and other design parameters to calculate pipe thickness required (Reference 3 of this letter) to sustain normal operating and peak detonation pressure.
Based on these calculations and with an additional factor of safety of 1.15 (Reference Table 1 of Calculation EC-072-1007),
there is enough pipe thickness margin leA in the existing o6gas piping system for Susquehanna Steam Electric Station, Units 18c2.
4 The stress in the pipe wall is a time dependent quantity; the pressure is applied suddenly.but the pipe wall does not respond instantly because of its inertia (Reference 4 of this letter).
General engineering practices were used to design component and component support for Susquehanna Steam Electric Station, Units 1 & 2. Based on operating history at other BWRs with similar offgas systems where oFgas detonations have occurred, no failure has occurred involving either component pressure boundaries or component supports.
- Hence, existing component and component support designs for Susquehanna Steam Electric Station, Units 1
&2 are acceptable based on both operating experience and Calculation EC-072-1007.
P. IO F AX NO, 6I07747540 ATI'ACHMENTTO PLA4882 Page 7 of 10 Question @t Following a postulated erplosion ofthe a+gas syst
@the follawlngconcerns; a.
the equlptnent (such as hydrogen analyzers, radiation monfors... etc) survivability, b.
tnonltorlng and controlling the release ofradloactNlty, and o.
operator actions.
Res ons to uestion56 a
The offgas hydrogen analyzers, pre-treatment radiation monitors and other instrumentation have the potential to fail following a detonation within the offgas pressure boundary.
The offgas system and related instrumentation is not safety related.
Failure ofthe equipment poses no personnel safety hazard.
Additionally, as a backup to the offgas pre-treatment monitor, the Turbine Building SPING stack monitor will alarm and prompt operator action to prevent exceeding occupational and offsite dose requirements.
Res onse to uestlon 06 The release of radioactivity &om the Offgas system will be monitored by the Turbine Building SPING monitor. Control ofreleases &omthe Turbine Building SPING viillbe accomplished under the existing procedures.
Res onseto uestionP6 c
Plant specific operator actions following an offgas detonation will be speci6ed in plant operating procedures prior to removing the offgas high hydrogen trip. GE Service Information Letter (SIL) 150 provided licensees general recommendations for operator action followingan indication of recombiner dHuent hydrogen in excess of 4%.
Key offgas system parameters including charcoal bed temperatures, offgas flow rate, recombiner temperatures, and pre treatment radiation monitors willbe evaluated in developing operating procedures.
Specific operator actions willdepend upon whether an offgas ignition occurs and whether the ignition results in a sustained combustion.
Operator actions following an ignition that will be evaluated include 1) shutdown and repair offailed components, or 2) addition ofinert gas to dilute the mixture below the flammable limit.
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I I ATTACHMENTTO PI.A<882 Page8of 10 References 1.
H. B. Sargent, "How to Design a Hazard-Free Sy, Fi re 2, Chemical Engineering, Pebnuuy 1957, pp 250-254.
2.
E. Lewis and 6. vcn Elbe, Combusriors Fhmes ond Expl
- pGam, Academic Press, Third Edition, 1987.
3.
ASME38rPV Code, Section VHI,ASMBBAPV Code, Section IQ, and ASME/ANSI831.1 Power Piping Code, 4.
P. N. Randall and I. Ginsburg, "Bursting of Tubular Specanens by Gaseous Detonation",
Journal ofBasic Engineering December 1961, pp 519-528.
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Table 1. Summary ofSusqgehanna Piping Analysis a
'I CCt I
CA
$ 41 ~ )<g '<Dr% M i.'.'.:: Qne ~metic@&
- KY&i%-'.N~.9'M
- DynazafcPtapcrcf~~-:.+~5-"-.-'=
6:,rrrl'-
sr~ aa xe:
GBC-N6 GBD-156 GBD-1$7 GBD-ISS HBD-115 YOR-10 VOR-)0 VOR.IO SA-)06, Gr B SA-)06 Gr 8 SA-106, Gr B SA-IO6, Gr B h-)06, Gr B A-106. Gr B A-106, Gr B A-)06, Gr B 16 0.500 8
0322 6
0.432 3
0300 3
0300 3
0300 4
0.337 6
0.432 8
0.322 6
02SO 6
02SO 8
0322 10 036S
>7
>7
>7
>7
>7
>7
>7
>7
>7
>7 152 152 1$2 152 1$.0 15.0 15.0 15.0 16.7 16.7 10.4 10.4 10.4 SO
)2)6 80 1216
)70 2584 170 2584 170 2550 170 2550 170 2550 170 ZSSO 17 284 17 17
)10 110.
110 I)0 70 70 140 140 140 140 60,4SS I)1.5)S 2.00 60,455 I)I,5IS 2.00 60,45511),515 2.00 60 4SS 111,5)S 2.00 63,000
)20,000 2.00 63 000
'120,000 2.00 63,000
)20 000 2.00 63.000 120,000 2.00
$&,S46 10$.151 2.00 58,546 105,151 2.00 58 546 IOS, IS) 2.00 58,546 105,15) 2.00 45,) 82 60,606 2.00 027 027 0.30 0.30 030 024 024 0.08 1.) 5 1.15 O.l 1.15 0379 1.15 0.189 I.)5 0.309 1.)S 0.154 13$
0.149 1.15 0.149
).lS 0.198 1.1$
0297 1.15 1.15 0.03 1.1$
0.
0203 0.102 0.164 0.076 018 0.012 0.013 0.144 SA-3)2, TP 316 4
O.OS6 SA-2 13, TP 316 0375 0.049
>7 15.0 15.0 17 170 2550 110 110 36,800
)71,000 2.00 36.800 171,000 2.00 O.n 0.
)3$
1.150.041 0.009 0.008 d
nominal pipe diameter, inches t
pipe mllthi~ inch L/D = length to diameter ratio p> = Operating prCSSurC pSia p = peak mtemaf detonatron pressure, psia T= operating temperature, 'P Sy = dynamic yield stress, psi {Ref4U)
Su = ultimate dynamic stress, psi (Ref4L5) h = dynamic loaf factor (Ref2) n = strain harderriog exponent (Rcf445)
F = arbitrary safety factor H'= thickness at yield point, inch (Ref 2) pdhF/l2.3 1(Sy-p) x 0.577'J H
perrr)anent deformation thickness, inch (Ref2) pdhF/[2.31(Su-p) x 0.57'P]
- 1. Thickness includes corrosion aQomace of0.080" for carbon steel and 0.003".for stainless steel.
- 2. UDsare based on the mfgas system isometric dxaaings, Reference 6.
- 3. Pressrrres are &na Reference 7.
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'y yJ
Figure I. Peak Pressure Ratio for Hydrogen Detonation 4" pipe 100 6" pipe P'ipe 24" pipe 0
0 10 15 35
~V p
C