ML20078P686
| ML20078P686 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/04/1983 |
| From: | Horin W, Reynolds N DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20078P690 | List: |
| References | |
| NUDOCS 8311080190 | |
| Download: ML20078P686 (6) | |
Text
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7 November 4, 1983 DOCKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'83 !ay -7 A9 :52 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD L i r i:C CT SECUTh 00C" w; A 39,.
M A Ci In the Matter of
)
)
Docket Nos. 50-445 and TEXAS UTILITIES GENERATING
)
50-446 COMPANY, et al.
)
~ ~ ~ ~
)
(Application for (Comanche Peak Steam Electric
)
Operating Licenses)
Station, Unit,s 1 and 2)
)
APPLICANTS' BRIEF REGARDING RELEVANCE OF BOARD NOTIFICATION 82-105A By Memorandum dated October 12, 1983, the Board invited the parties to file briefs regarding the relationship to this proceeding of Board Notification 82-105A, "NRC Staff Evaluation Regarding Allegations of Potential Design Deficiencies in Class I Piping" (September 29, 1983).
The Board indicated that it is particularly interested in the relationship between the Board Notification and the discussion in the NRC SIT Report regarding the use of U-bolts in pipe support design.
Accordingly, Applicants provide the following brief.
As shown below, the Board Notification is not relevant to the SIT Report discussion.
I, BACKGROUND One aspect of the allegations made in this proceeding regarding pipe support design concerned the use of U-bolts in pipe clamps at Comanche-Peak.
The NRC Staff evaluated this
~
allegation in detail and submitted a report by a Special h0dIk$0cx030oo443 I90 831104 o
,y'P
1
. Inspection Team (" SIT") which addressed, inter alia, the allegations concerning the use of U-bolts (NRC Exhibit 207 at 29-34).
Extensive hearings have been conducted regarding the pipe support design allegations and the parties have now filed proposed findings.1 i
Prior to issuing BN 82-105A, the Staff had also issued Board Notification 82 105, " Alleged Designed Deficiencies" (November 24, 1982).
Therein, the Staff described an allegation to the Commission regarding design deficiencies in certain pipe clamps used on ASME Code Class I piping.
BN 82-105 did not describe ihe type of clamp involved in the allegation.
At the request of the Board, the Applicants and the NRC Staff filed affidavits addressing BN 82-105.2 In their affidavits, the Staff and Applicants described the type of pipe clamp to which,BN 82-105 referred and indicated that Applicants were undertaking an analysis of the effect of those clamps on Class I piping.
The Board has now invited additional information on this topic, in response to BN 82-105A.
That Notification discusses the results of the Staff's investigation and evaluation of the 1
See Applicants' Proposed Findings of Fact in the Form of an Initial Decision (August 5, 1983); CASE's Proposed Findin of Fact and Conclusions of Law (Walsh/Doyle Allegations) gs (August 30, 1983); NRC Staff Proposed Findings of Fact in the Form of a Partial Initial Decision (August 30, 1983; see also Applicants' Reply to CASE's Proposed Findings of Fact and Conclusions of Law (September 6, 1983).
2 See Af fidavit of John C.
Finneran, Jr.,
Regarding Analysis of Pipe Clamps Designated in Board Notification 82-105 (May 5, 1983), transmitted by Applicants to Board under cover letter dated May 5, 1983; Affidavit of David Terao (May 4, 1983) transmitted to Board by NRC Staff under cover letter dated May 6, 1983.
. allegations regarding the use of " stiff" pipe clamps on ASME Code Class I piping.
The Board has indicated it would like the parties to address the relationship of BN 82-105A to the Comanche Peak proceeding, particularly with respect to the SIT Report analysis of U-bolts used in pipe clamps (NRC Exhibit 207 at 29-34).
l As shown below and in the attached affidavit of Mr. John C.
Finneran, Jr., the concerns regarding the pipe clamps addressed in BN 82-105A are not related to the use of U-bolts in conventional pipe clamps which are the subject of the allegations regarding U-bolts addressed in the SIT Report.
In addition, we discuss below Applicants evaluation of the stresses imposed by the stiff pipe clamps used on Class I piping at Comanche Peak.
II.
RELEVANCE OF BN 82-105A A.
BN 82-105A is Not Relevant to SIT Report As discussed in the attached affidavit of John C.
- Finneran, Jr., BN 82-105A does not concern the conventional pipe clamp systems which were the subject of the pipe support design allegations addressed in this proceeding and evaluated in the SIT Report at pp. 29-34.
The pipe clamps addressed in BN 82-105A are relatively new " stiff" clamps developed to satisfy certain dynamic load considerations.
These " stiff" clamps induce preloading stresses in piping which are much greater than those in conventional pipe clamp systems (see BN 82-105A at II-4 to II-5, IV-5 and VI-l to VI-2).
(Finneran Affidavit at 4.)
-- On the other hand, the SIT Report addresses specific allegations regarding the use of U-bol ts in conventional clamping systems.
Although some stiff pipe clamps also utilize U-bolts in their design, the concern expressed in BN 82-105A is not with the fact that U-bolts are used, but rather with the high preloading and other stresses which are induced by stiff pipe clamps (whether or not by U-bolts) (see BN 82-105A at IV-5).
The Staff clearly states in BN 82-105A that its concern is not with the conventional pipe clamps, where " low magnitude stresses" do not require special analysis, but rather with the "relatively new type of pipe clamp commonly referred to as a ' stif f' pipe clamp" (BN 82-105A at VI-l and Enclosure 2 at 1-2).
The SIT Report evaluation of conventional pipe clamp systems utilizing U-bolts is fully consistent with BN 82-105A.
(Finneran Affidavit at 4-5.)
In sum, the concerns addressed in BN 82-105A do not relate to the allegations made in this proceeding regarding the use of U-bolts in conventional pipe clamp systems.
Accordingly, the evaluation and resolution of the matters raised by BN 82-105A will not affect the Board's consideration of the pipe support design allegations in this proceeding.
I i
t
. B.
Evaluation of Stiff Pipe Clamps Demonstrates That No Serious Safety Concern is Presented i
l None of the matters addresscd in BN 82-105A raise a serious safety concern regarding the use of pipe clamps at Comanche Peak.
As discussed in the attached affidavit of John C.
- Finneran, Applicants have already evaluated the concerns expressed in BN 82-105A regarding the use of stiff pipe clamps on Class I piping.
l Applicants' evaluation employed conservative assumptions and calculational techniques to assess the stresses which arise from the use of those pipe clamps.
That evaluation, which will be subject to Staff review and confirmation, demonstrates that the stresses imposed by those clamps will not exceed applicable ASME stress limits.
(Finneran Affidavit at 2-3.)
In addition, although BN 82-105A does not concern the use of stiff pipe clamps on other than Class I piping, Applicants intend to work with the Staff to provide adequate assurance that the use of these clamps on other piping does not present a safety concern (Finneran Affidavit at 3).
The Staff will, of course, continue to monitor and assess this matter to confirm that no safety concern is presented by the use of stiff pipe clamps at Comanche Peak.
In sum, the use of stiff pipe clamps at Comanche Peak is being properly addressed and the evaluation of the effects on Class I piping indicates that no safety concern is presented.
Further consideration of this matter will be subject to careful monitoring and confirmation by the Staff.
Accordingly,
__ there is no basis for concluding that a serious safety concern is presented that would justify further Board consideration of this matter (see 10 C.F.R. $2.760a).
III.
CONCLUSION Based on the foregoing, the Board should find that the 1
concerns raised in BN 82-105A are not related to the issues raised in this proceeding regarding pipe support design.
In addition, the Board should conclude that no serious safety concern is presented by BN 82-105A that justifies further Board consideration of this matter.
Respectfully submitted, 1
Nicholao
.F.eynolds
- t w)
]
Willj.am A.
Horin V
Counsel for Applicants DEBEVOISE & LIBERMAN 1200 Seventeenth Street, N.W.
Washington, D.C.
20036 (202) 857-9817 November 4, 1983 l
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