ML19326D143

Responds to NRC 760113 Addl Info Request Re Reg Guide 1.20, 1.48 & 1.67 Implementation.Mechanical Engineering Guides Were Discussed on 751118

ML19326D143
Person / Time
Site:	Midland
Issue date:	02/03/1976
From:	Bauman R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Boyd R Office of Nuclear Reactor Regulation
References
NUDOCS 8006060720
Download: ML19326D143 (7)

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. - CDE?Eirf General Omces: 212 West Micmsgan Avenue, Jackson, MicMigan 49201 e Area Code 517788 0550 February 3,1976

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O'i Director of Nuclear Reactor Regulation g; ,, ,

Attention: Mr Roger Boyd, Director *- l r.,J 9

• Division of Project Management U. S. Nuclear Regulatory Commission Washin6 ton, DC 20555 h{k A ugg^'*'

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MIDLAND PROJECT DOCKET NUMBERS 50-329, 50-330 REGULATORY GUIDE IMPLEMENTATION FILE: 0505 SERIAL: 2122 The enclosed infor=ation responds to Mr A. Schwencer's January 13, 1976 letter requesting additional infomation on i=plementation of Regulatory Guides for the Midland Plant. These guides deal with mechanical engineering and were dis-cussed with your staff on November 18, 1975 r _. ~

R. C. Bauman /c a , -  :

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THIS DOCUMENT CONTAINS POOR QUAUTY PAGES

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110.0 MECHANICAL ENGINEERING 110.1 Regulatory Guide 1.20 (Vibration Measurements on Reactor Internals)

The degree of conformance with Regulatory Guide 1.20 (Safety 4 Guide 20 - Vibration Measurements on Reactor Internals) is not complete. Please indicate conformance with Regulatory Position D.4 in addition to your stated intention to comply with Regulatory Positions D.1 and D.2 or provide justification for suitable alternatives.

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Response

A summary report, in the form discussed in Part C.5 and/or C.6, of a visual inspection performed in accordance with Part D.2,

' will be submitted to the Commission after the completion of the inspection.

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110.2 Regulatory Guide 1.48 (Design Limits and Loading Combinations)

I. Equipment Purchased Prior to July 1, 1975

1. The discussion on implementation of Regulatory Guide 1.48 pertaining to operability of active pumps and valves supplied by both B&W and BOP purchased prior to July 1, 1975 is not complete. We recommend that the operability of active pumps and valves be assured ,

by testing those appurtenances crucial to the actuation of active pumps and valves subjected to faulted condition' loads.

II. Balance of Plant Equipment Purchased After July 1, 1975

1. The design loading combinations for ASME Class 1, 2 and 3 components specified in Table.7, Sheet 19, for the faulted condition is not consistent with the currently acceptable definition of faulted load condition, i.e., PO + DW + DF + SSE. Please provide clarification or modification of the information in Table 7 to be consistent with the currently acceptable faulted condition load combination.

2. The Standard IEEE-344-1971 is not entirely adequate for the seismic qualification of Category I instru-mentation and electrical equipment purchased after July 1, 1975. Guidelines for the seismic qualification of Category I instrumentation and electrical equipment are specified in Section 3.10 of the NRC Standard Review Plan.

III. B&W Equipment Purchased After July 1, 1975 The degree of conformance with Regulatory Guide 1.48 of B&W equipment purchased after July 1, 1975 is not clear.

We recommend that all B&W active components purchased after July 1, 1975 be qualified for operability at least to the same degree proposed for balance of plant equipment purchased after July 1, 1975.

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110.2 cont'd -

Response

Balance of Plant and NSS Scope of Supply I.l. The applicant does not concur with the Staff's recommendation for new testing on purchased components.

The addition of new requirements to issued purchase

, orders would greatly perturb component delivery schedules in that it would require: 1) the modification and reissue of design specifications, 2) the development of new vendor test procedures and applicant review and approval of these procedures,-3) scheduling of the new tests into vendor shop scheduler., and 4)

reopening of contract negotiations to resolve the commercial questions raised by any new requirements.

The applicant foresees difficulties in attempting to impose tests which were not part of the equipment specification bid on by the vendors. It is our experience that vendor shop capabilities to perform the recommended additional tests may not exist at this time. The applicant therefore contends that the imposition of new test requirements on previously purchased equipment currently in various stages of manufacturing and shipment would represent an undue hardship'not being required of other Oconee class plants.

II.1 Load combinations as stated in the applicant's response, Table 7 for the faulted condition, differ from the NRC position as stated in Regulatory Guide 1.48. Specifically, the NRC requires that components be designed for "... concurrent loadings: associated

' with the normal plant condition, the vibratory motion of the SSE, and the dynamic system loadings associated with the faulted plant condition."

The applicant's position requires concurrent loadings only if it can be reasonably assumed that the component stress levels are additive and that this addition could cause a deleterious effect.

The following clarifications are provided in substantiation of the applicant's position. These statements are keyed to the faulted load combinations of Table 7 of the applicant's Regulatory Guide Position.

Faulted Condition (a)

It may be reasonably assumed that an SSE could cause

} a plant trip from full power which would (in the case 3

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of a PWR) lift the steam generator relief valves (open discharge system). It is also reasonable to assume that the relief valve blowdown could cccur for a significant period of time during the SSE duration.

If the above sequence occurs the stresses produced in the system by the two events will be a maximum at the same time and should be combined and evaluated in accordance with ASME faulted condition stress limits. Note that the relief valve blowdown produces a steady state load while the SSE causes a vibratory load.

Faulted Conditions (b) and (c)

As opposed to conditior. (a), where two "cause and effect" events occur (one steady state and one vibratory); conditions (b) and (c) consider two completely unrelated events (one vibratory (SSE) and one short duration transient (DF) ) .

Since there is no "cause and effect" related to the DF and the SSE, the joint probability of these two unlikely events occurring simultaneously is extremely low.

In addition, the probability of the two independent events producing their individual maximum stresses (1) at the same point in the system, (2) at the same instant in time, and (3) with the displacements inphase, is so remote that it should not be included as criteria for ASME component design.

11.2. Sheet 7 of the response for balance of plant equipment purchased after July 1, 1975 will be corrected to read "IEEE Standard 344-1975." The applicant believes that this meets the current NRC requirements.

III. No NSS scope of supply equipment has been purchased since July 1, 2975, that is required to meet the requirements of Regulatory Guide 1.48. In addition, no equipment within the B&W scope of supply remains 1 to be procured, which would be subject to requirements j of this Guide. <

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110.3 Regulatory Guide 1.67 (Installation of Overpressure Protection Devices)

The discussion of Regulatory Position C.4 pertaining to the calculation of dynamic amplification factor and determination-of response to forced vibration is acceptable. The statement "in lieu of the above procedure, sometime history dynamic calculation may be used" is not clear. The current practice is to allow the use of a DLF (dynamic load factor) of 2.0 in lieu of a dynamic analysis to determine the actual value of the DLF.

. Response The statement ". . .in lieu of the above procedurr., some history dynamic calculation may be used" will be deleted from our response when the response is submitted as a PSAR amendment.

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, NRC,0{STRIBUTION FOR PART 50 COCKFT MATERI AL.

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(TEMPORARY FORM)

CONTROL NO:.f_

FILE:

FROM: Consumers Pwr Co DATE OF DOC DATE REC'D LTR TWX RPT OTHER Jackson, Mientgan R C Bauman 2-3-76 2-y-70 XX TO: ORIG CC OTHER SENT NRC PDR XX DL one signed '

SENT LOCAL PDR

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CLASS UNCLASS PROPINFO INPUT NO CYS REC'D DOCKET NO:

XXX 1 ,.30.-3 2'h(3 30 DESCRIPTlON: ENCLOSURES:

Addl supplemental info concert:1ng reg G21d

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Ltr re our 10-30-75 ltr...trans the following:

........ responding.coquestion321.2......J (10 cys encl rec'd)

. PLANT N AME: niciand 1 &'2 SAFFTy #- W- # *"I FOR ACTION /INFC dMATION mf i ,n AS33GNED AD ASSICTED LRANCH Ch1EF BRANCH ClllEF PROJECT MA'iACER PROJECT M/JTACER [ cc - c' llc ASST. W/ ACRS

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LIC. ASST. U/ CYS ACRS INTERNAL DISTRl0UTIOT4 h C PIL D SYSTEMS SAFFTY PLANT SYSTEMS SITE SATLTY & ENVIRO ANALYSIS

/,f NRC PDR IIEIt:EMAN TEDESCO 'DENTON MULLER OELD SCliR0EDER DENAR0YA COSS1CK/ STAFF LAINAS ENV]RO TECH. SITE ANALYSlS jI&E (2) ENGlf;EER ING IPPOLITO ERNST VOLLMER MIPC MACCARY BALLARD EUNCII

,/KNIGilT OPERATING REACTORS SPANGLER J. COLLINS Pno.TECT M.U AGEMENT SIH'JEIL STELLO KREGER E0YD PAWLICKI SITi!

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P. COLLINS OPERAT11C TEClf. CRt1ILL AT&I

!!0USTON REACTOR SAFETY EISENHUT STEPP SALTZMAN PETERSON ROSS SHA0 HULMAN RUTEERG MELTZ NOVAK BAER HELTEMES ROSET0CZY ." SCirJENCER MISCELLANEOUS CHECK CRIMES ...

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EXTEgNAL DISTRIBUTION LOCAL PDR/lI'J ! 4

" /// NATIONAL LAT U/ CYS ER00R11AVEN MAT. LAD

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NSIC LA PDR ASLB CONSULTANTS

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