ML19207B995

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Submits Outline of Procedures for Handling safety-related Process Instrumentation Tubing Mounting,Due to Lack of Regulatory or Industry Guidelines.Requests NRC Review & Concurrence
ML19207B995
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 08/28/1979
From: Gary R
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To: Baer R
Office of Nuclear Reactor Regulation
References
10010, NUDOCS 7909060287
Download: ML19207B995 (2)


Text

Log # TXX-3035 File 10010 TEXAS UTILITIES GENERATING COMPANY 2001 BRYAN TOW ER. DALLAS. TEXAS 75201

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August 28, 1979

.,c Mr. Robert L. Baer Chief Light Water Reactors Branch No. 2 Division of Nuclear Reactor Regulation U. S. Nuclear Regulatory Comission Washington, D.C.

20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION SAFETY-RELATED PROCESS INSTRUMENTATION TUBING MOUNTING

Dear Mr. Baer:

In the course of designing and constructing Comanche Peak Steam Electric Station (CP5ES), it has been identified that there is a lack of regulatory or industry guidance on safety-related process instrumentation tubing mounting and code applicability. Further, a description of the methods for handling this equipment is not required in Regulatory Guide I-70 " Standard Fomat and Content for Safety Analysis" or in the Standard Review Plans.

In light of this situation, Texas Utilities Generating Company (TUGCO) wishes to inform the Staff that the following approach is being taken on CPSES:

1.

All tubing connecting process instruments to ASME III Class 2 and 3 piping are being seismically supported.

NOTE: The CPSES design does not include any ASME III, Class 1 process instrument tubing.

2.

All tubing connecting safety-related process instruments to nor-ASME III piping or duct work are being seismically supported.

3.

All instrument tubing, valves and fittings forming ASME III Class 2 or 3 pressure boundaries will be purchased, installed and tested in accordance with the requirements of ASME III Class 2 or 3.

4.

The seismic tubing support design considers movements of the connecting piping in relation to the tubing.

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Mr. Robert L. Baer August 28, 1979 TXX-3035 5.

Any welding of seismic tubing supports is per AWS specifica-tion consistent with that perfonned on other non-ASME supports.

6.

The boundary of jurisdiction of ASME code section III, subsection NF is taken at the instrument root valve.

7.

The Quality Assurance program governing these supports is the approved QA program governing non-ASME work.

8.

The material used for fabrication of seismic instrument tubing supports is purchased with certificates of compliance to applicable ASTM standards.

9 _.

Existing seismically designed support systems such as cable tray hangers or conduit supports will be used for tubi ng. suppo rts. Any necessary re-analysis will be per-fonned to-justify the additional loads.

TUGC0 believes this approach is consistent with the need to ensure the integrity of the instrumentation tubing for safety applications to protect the health and safety of the public.

This information will be included in a future amendment to the FSAR.

The above procedure for handling safety-related process instru-mentation tubing mounting is being forwarded for your review and concurrence. Your expeditious response in this matter is requested.

If we can provide additional information, please contact this office.

Sincerely yours, R.

. Gary RJG:skf cc:

H. C. Schmidt R. J. Gary - 2c D. N. Chapman J. C. Kuykendall J. T. Merritt N. S. Reynolds R. L. Estes ARMS s.i a' m cA 1">

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