ML20029D900

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Summary of 940426 Meeting W/Util & W in Rockville,Md Re TMI Issue II.d.1, Performance Testing of BWR & PWR Relief & Safety Valves. Attendees List & Handout Encl
ML20029D900
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 05/09/1994
From: Siegel B
Office of Nuclear Reactor Regulation
To:
Office of Nuclear Reactor Regulation
References
TASK-2.D.1, TASK-TM TAC-M84666, TAC-M84667, NUDOCS 9405120154
Download: ML20029D900 (20)


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NUCLEAR REGULATORY COMMISSION i

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WASHINGTON, D.C. 20555-0001 g

  • s, May 9. 1994 Docket Nos 50-348 and 50-364 LICENSEE:

Southern Nuclear Operating Company-FACILITIES:

Joseph M. Farley Nuclear Plant, Units 1 and 2

SUBJECT:

MEETING

SUMMARY

RELATED TO TMI ISSUE II.D.1 (TAC NOS. M84666 AND M84667)

On April 26, 1994, a meeting was held with Southern Nuclear Operating Company (SNC or the licensee) and Westinghouse at the NRC Offices at One White Flint North in Rockville, Maryland, to discuss resolution of TMI Issue II.D.1,

" Performance Testing of BWR and PWR Relief and Safety Valves".

The purpose of the meeting was for SNC to address staff concerns contained in a March 23, 1994, letter related to the licensee's October 12, 1993, response to the staff's request for additional information (RAI) on this issue.

contains a list of meeting attendees and Enclosure 2 contains a copy of the-licensee's handout.

In response to the RAI the staff identified several technical deficiencies in the licensee's analysis.

Specifically, SNC attempted to justify the existing design by the use of a non-linear analysis method, did not follow the load combination guidelines developed by the Electric Power Research Institute (EPRI) and did not use a technically appropriate. method of combining responses i

from the non-linear analysis. The licensee requested the meeting to clarify the information contained in its October 12, 1993, response and to obtain a better understanding of the staff's concerns. On the bases of the discussions with the technical staff during the meeting, SNC is going to modify its analysis to determine if some localized stresses in the piping down stream of 1

the power-operated relief valves can be reduced to meet faulted conditions and if a minimum safety factor of three on the anchor bolts can be achieved.

If the stresses cannot be reduced to acceptable limits, SNC has stated that modifications to the existing discharge piping will be made to withstand the loads '(i.e., removal of whip restraints and reinsulation or elimination of the loop seal).

The licensee has agreed to either provide the results 9405120154 940509

/1 PDR ADOCK 05000348 l l; P

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May 9, 1994 Meeting Summary of its reanalysis'or a commitment to make modifications within 90 days of the meeting date.

If SNC proposes modifications a schedule for implementation will be included.

ORIGINAL SIGNED BY:

Byron L. Siegel, Project Manager Project Directorate 11-1 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation

Enclosures:

1.

List of Participants 2.

Licensee Handout cc w/ enclosures:

See next page l

1 0FFICE LA:PD21:DRREhlPM:fD2hBAPE,

PDgPD21:,DR_PE s

NAME PAnderso}i W BSie N NtmSn DATE O/Y/94 7/N94 8 / 9 /94 0FFICIAL RECORD COPY Document Name: G:\\FARLEY\\FAR84666\\MTS 4

S MEETING

SUMMARY

'0F April 26, 1994 DISTRIBUTION w/ enclosure 1 W. Russell /F Miraglia L. Reyes S. Varga G. Lainas W. Bateman B. Siegel P. Anderson 0GC E. Jordan C. Craig A. Thadani

- R. Zimmerman ACRS (10)

L. Plisco DISTRIBUTION w/ enclosures 1 & 2 Docket File PDR & LPDR PD 11-1 Reading File E. Mershoff, Region II J. Fair G. Hammer 4

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Meeting Summary of its reanalysis or a commitment to make modifications within 90 days of the meeting date.

If SNC proposes modifications, a schedule for implementation will be included.

B on L. Siege, Project Manager oject Directorate 11-1 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation

Enclosures:

1.

List of Participants 2.

Licensae Handout cc w/ enclosures:

See next page i

I i

i

- c Joseph M. Farley Nuclear Plant cc:

Mr. R. D. Hill, Jr.

State Health Officer General Manager - Farley Nuclear. Plant Alabama Department of Public Health Southern Nuclear Operating Co., Inc.

434 Monroe Street Post Office Box 470 Montgomery, Alabama 36130-1701 Ashford, Alabama 36312 Chairman Mr. B. L. Moore, Licensing Manager Houston County Commission Southern Nuclear Operating Co., Inc.

Post Office Box 6406 Post Office Box 1295 Dothan, Alabama 36302 Birmingham, Alabama 35201-1295 Regional Administrator, Region II James H. Miller, III, Esquire U. S. Nuclear Regulatory Commission Balch and Bingham Law Firm 101 Marietta St., N.W., Ste. 2900 Post Office Box 306 Atlanta, Georgia 30323 1710 Sixth Avenue North Birmingham, Alabama 35201 Resident Inspector U.S. Nuclear Regulatory Commission Mr. D. N. Morey Post Office Box 24 - Route 2 Vice President Columbia, Alabama 36319 Southern Nuclear Operating Co., Inc.

Post Office Box 1295 Birmingham, Alabama 35201-1295

April 26. 1994 TMI Issue II.D.1 Meetina list of Attendees HAME ORGANIZATION Byron Siegel NRR/DRP/PDII-I John Fair NRR/DE/EMEB Richard Morrison Westinghouse / Licensing Jeff Himler Westinghouse / Structural Eng.

Gary Hammer NRR/DE/EMEB T.H. Liu Westinghouse / Piping Eng Brad Moore SNC Licensing Paul Hayes SNC Licensing D.V. Jagannath Bechtel Plant Design M. Khianey Bechtel Plant Design

ENCLOSURE 2 NRC MEETING ON TMI ACTION NUREG-0737. II.D.1 For Farley Units 1 and 2 Introduction Historical Background NRC SER of 1986 1992 Elastic and inelastic Analyses Response to NRC Request for Additional Information b

3484e.fmk(940425):501

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INTRODUCTION Present FNP analysis confirms compliance with II.D.I by demonstrating that as-built discharge piping will not affect PZR safety valve operability.

Further physical changes require significant dose exposure and expenditure without a corresponding benefit to safety.

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HISTORICAL BACKGROUND 10/80 -

NUREG-0737 TMI action plan requirement issued.

EPRI test program results (7/81).

Plant specific submittal (1/82).

Completion of design basis analysis by 5/81 Westinghouse for Class 1 piping.

Farley past actions in addressing NUREG-0737 II.D.1

- 1/81 APCo initial response to NUREG-0737.

- 2/81 APCo clarification response to NUREG-0737.

- 6/81 APCo commitment to EPRI test program.

- 9/81 NRC request of evaluation supported by test re.sults to be submitted by 7/82.

- 4/82 APCo is a participant of EPRI generic PWR safety and relief valve test program. Valve tested by EPRI represent the Farley design and operating conditions. APCo committed plant specific evaluation done by 7/82.

- 7/82 APCo committed to complete further analysis of the downstream loads based on EPRI test program.

3484e.fmk(940425):50 3

I 11/82 APCo presented.W analysis report based on cold loop seal and using a very conservative evaluation criteria from EPRI test program (WCAP-10105) and its piping sub-committee recommendations. Potential overstress predicted in the NNS piping but concluded the overstress will not effect the operation of pressurizer nozzle, the inlet line, the safety valve. APCo considered the 7/82 commitment satisfactory.

12/86 In its SER, NRC expressed concern on the overstress condition stated in 11/82 submittal. Specific concerns were severe deformation in NNS piping would affect the operability of the safety valves and l

acceptable code qualification.

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2/87 APCo committed to perform cost benefit study between options of plant modification and additional analysis. Schedule of resolution would be provided.

9/88 APCo informed NRC of alternative approach by raising the loop seal temperature (hot loop seal) via insulation in order to lower the stress in NNS piping. (Hot loop seal not completely obtained due to constraints in pressurizer cavity.)

3484e.fmk(940425):50-4

Current Issue in Addressing NUREG-0737 II.D.1 8/92 APCo submitted the current W elastic plastic analysis report based on variable loop seal and using a very conservative evaluation criteria from EPRI test program (WCAP-10105) and its piping sub-committee recommendations. To address NRC concerns in 12/86 SER, report concluded that only small plasticity predicted in the NNS piping and the piping will not collapse nor kink. It will maintain fully operable even at the conservative postulation of three safety valves open simultaneously.

1993 APCo response to NRC 1st round inquiry.

1994 NRC 2nd round inquiry.

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NRC SER of 1986 Approval of Farley 1982 Analysis bounding loading case was chosen (met item 3 of Section 1.2; maximum dynamic forces).

accepted load combination and acceptance criteria.

piping and support analysis verified that item 8 had been met for relief valve piping; safety valve piping up to ist support past the safety valve outlet on the discharge piping (essentially ASME Class 1 piping).

Remaining Issues on the rest of the discharge piping (NNS piping)

Safety valve operability could be affected by severely deformed pipe that would restrict flow.

To meet ANSI B31.1 requirement for emergency and faulted conditions for the seismically designed piping in order to satisfy the requirembnt of NUREG-0737.

3484e.fmk(940425).50-6

4 1992 ANALYSIS The need for 1992 Analysis Variable loop seal condition was obtained from field insulation instead of hot loop seal.

Address issues raised in NRC SER Demonstration of valve operability by showing no restriction of flow and meeting structural integrity for the NNS piping criteria.

Qualification of discharge piping to B31.1 criteria.

APCO's Position The intent of item II.D.1 from NUREG 0737 is met by demonstration that NNS piping will not be deformed such that there is any impact on the operation of the safety valve.

l 34sde Ank(940425) 50-7

6 1992 ANALYSIS FLOW DIAGRAM FSAR Classified NNS Piping of SV Discharge lf Hydraulic Forcing Function from Variable Iq Seal (40 msec for valve opening time; V

V V

inelastic Piping System Analysis Elastic Piping System Analysis V

V Pipe Strain Evaluation to address SER concem using structuralintegnty criteria y

y Pipe Stress Evaluation based on EPRI Pipe Support Structural Component ppng sutgar retiee recommended Evaluation based on structural integrity U

cntena criteria for NNS supports Very low strain from valve thrust loads faulted ( I Faulted (d Total strain <0.5%

(Elbow & Reducer)

No combinahon with SSE due to independent events V

U U

SER concem satisfied based on Pipe Stress Evaluation based on Base Plate Anctor Bolts Evaluation structuralintegnty criteria, structuralintegrity criteria based on structural integrity aiteria No hinge formation (+/)

Base Plate Faulted (e )

r Iow strain in pipe (+/)

  • * (d (05%)

with min. SF - 1.4 (Based on Faulted Load) i 3484e Imh(940425)50-8

RESPONSE TO INQUIRY #1 1

ITCHVALVE/ITCHVENT COMPUTER PROGRAMS Thermal hydraulic code.

Benchmarked to EPRI test program results.

WECAN Computer Program structural analysis code.

elastic / plastic analysis elements documented, verified, and benchmarked.

elastic / plastic analysis conservative.

verification problems are listed in WECAN User Manual, Table 5-2, Volume ll. They can be submitted to NRC for reviews if requested.

3464e.fmk(940425).50 9

RESPONSE TO INQUIRY #2 1

1986 SER approved load combination and acceptance criteria EPRI Piping Sub-committee of PWR PSARV Test Program The recommended load combination for Class 1 piping (WCAP-10105).

Relief valve discharge (upset transient)

- N, Rv < Level B.

Safety valve discharge (emergency transient)

- N, SV, < Level C Safety valve discharge in conjunction with SSE and LOCA (faulted)

- N, SV, SSE, LOCA < Level D Use SRSS for combining dynamic responses For NNS piping.

Option 1 -

Similar combination as Class 1 Piping using Class 2,3 rules.

Option 2 -

Structural Integrity Criteria No failure or restriction of flow are allowed.

3484e.imk(940425):50-10

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I RESPONSE TO INQUIRY #3 EPRI PWR PSARV Test Program Results (1982) were used for the benchmarking of ITCHVALVE.

hydraulic forcing functions generated are conservative.

structural analysis results from WECAN Code with hydraulic forcing function input are conservative.

NNS Piping Needed only for Discharge of the Flow structural integrity criteria should be allowed.

criteria from EPRI Piping Subcommittee (1982) is unrealistically conservative.

b

t RESPONSE TO INQUIRY #4 SRSS combination of results from elastic and elastic /

plastic analyses are not used.

The combination of SSE with SV loads by SRSS method only for loads from elastic analysis results. No elastic / plastic analysis results were used in support or embedment evaluations.

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_.l RESPONSE TO INQUIRY #5 All anchor bolts with less than SF = 4 are in NNS piping.

Structural integrity criteria should be allowed for NNS piping with the following reasons:

ensure proper delivery of flow after valve actuation.

simultaneous opening of 3 safety valves is a very conservative assumption.

extremely low number of actual safety valve actuations in operating plants.

for factored loadings (accident / extreme environmental loads), safety factors of 1.2 and 3.0 are used commensurate with the provisions of Section B.7.2 of ACI-349-90 and its supplement of 3/90. FS=1.2 for bolt material; FS = 3.0 for concrete shear cone.

high FS is required only for the failure mechanism of concrete shear cone not the bolts.

AISC Specification: FS = 1.7 for service loadings, FS = 1.1 for accident / extreme environment loadings.

3484e.fmk(940425).5013

RESPONSE TO INQUIRY #5 (cont.)

APCo has implemented 100% verification ~ testing in IEB 79-14/79-02 program with total quality control.

pull-out capacity increases with concrete aging.

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