ML20083K027

Forwards Response to Items 13 & 17 of 840222 Brief Summary of Generic Problem from J Doyle & Items 4 & 6 of Brief Summary of cross-examination Questions from M Walsh Re Independent Assessment Program

ML20083K027
Person / Time
Site:	Comanche Peak
Issue date:	03/07/1984
From:	Williams N CYGNA ENERGY SERVICES
To:	Ellis J Citizens Association for Sound Energy
References
84042.03, NUDOCS 8404160035
Download: ML20083K027 (7)

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101 Cahfornia Street. Suite 1000, San Francisco, CA 941115894 415 397 5600 March 7,1984 84042.03 Mrs. Juanita Ellis, President Citizens Association for Sound Energy [p- M g 1426 South Polk Dallas, Texas 75224

Subject:

Comanche Peak Steam Electric Station independent Assessment Program -

Response to CASE Ouestions

Reference:

(I) Brief Summary of Generic Problems from CASE Witness Jack Doyle,2/22/84.

(2) Brief Summary of Cross-examination Questions from CASE Witness Mark Walsh,2/22/84.

Dear Mrs. Ellis:

Enclosed please find our responses to reference (l) items 13 and 17, and reference (2) items 4 and 6. We are continuing to complete the remaining responses and anticipate sending another partial set next week.

Very truly yours, Ia#

Nancy H. Williams Project Manager NHW:eam

Enclosures:

Attachment A, Partial Responses to CASE Questions cc See attochment v

I 0404160035 840307 PDR ADOCK 05000445 A PM l ll Sa.. Francisco Boston Chicago Richland

=-.-,c Mrs. J. Ellis March 6,1984  !

Response to CASE Ouestions Attachment j Nicholas S. Reynolds, Esq. Mr. John T. Collins Bishop, Liberman, Cook, Purcell & Reynolds U.S. NRC, Region IV l 1200 Seventeenth Street, N.W. 61i Ryan Plaza Drive l Washington, D.C. 20036 Suite 1000 Arlington, Texas 76011 ,

Robert Wooldridge, Esq.

Worsham, Forsythe & Sampels Mr. Lonny Alan Sinkin 2001 Bryan Tower i14 W. 7th, Suite 220 Dallos, Texas 75201 Austin, Texas 78701 Mr. Homer C. Schmidt B. R. Clements Monoger - Nuclear Services Vice President Nuclear Texas Utilities Generating Company Texas Utilities Generating Company 2001 Bryan Tower Skyway Tower Dollos, Texas 75201 400 North Olive Street L.B. 81 Mr. H. R. Rock Dollos, Texas 75201 Gibbs & Hill,Inc.

393 Seventh Avenue Peter B. Bloch, Esq.

New York, New York 10001 Chairman, Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Mr. A. T. Parker 4350 East / West Highway,4th Floor Westinghouse Electric Corporation Washington, D.C. 20814 P.O. Box 35S Pittsburgh, Pennsylvania 15230 Dr. Walter H. Jordon 881 W. Outer Drive Reneo Hicks .Ook Ridge, Tennessee 37830 Assistant Attorney Genero!

Environmental Protection Division Dr. Kenneth A. McCollom P.O. Box 12548, Capitol Station Dean, Division of Engineering Architecture and Austin, Texas 787II Technology Oklahoma State University Mr. James E. Cummins Stillwater, Oktohoma 74074 Resident inspector / Comanche Peak Nuclear Power Station Stuart A. Treby, Esq.

c/o U.S. Nuclear Regulatory Commission Office of the Executive Legal Director P.O. Box 38 U.S. Nuclear Regulatory Commission Glen Rose, Texas 76043 Washington, D.C. 20555 y hsiS. Burwell Mr. J. B. George Licensing Project Manager Texas Utilities Generating Company U.S. Nuclear Regulatory Commission Comanche Peak Steam Electric Station 7920 Norfolk ,Avenus Highway FM 201 Bethesdo, Maryland 20014 Glen Rose, Texas 76043

- Mr. H. Schmidt Mr. David H. Wade c/o Westinghouse Texas Utilities Generating Company 4901 Fairmont Avenue 2001 Bryan Tower Bethesda, Maryland 20814 Dollas, Texas 7520I Mr. David R. Pigott Orrick, Herrington, & Sutcliffe 600 Montgomery Street Son Froncisco, California 941II

Comanche Peak ASLB Hearings Response to CASE Questions Question No.,Doyle //I3

• Exhibit No. 891 1.0 CASE Question in Note 2 following pages PS-01-4 of 4 , Cygno decided to eliminate their stiffness criterio based on their knowledge that a report existed to address the problem (but without personal knowledge of what was contained in the document in detail). Why didn't Cygno consult with their experts - for example Eric von Stijgeren (who was the editor on a paper by T.Y. Chow, C.H. Chen and O. Bilgen) - in reference to deviations from generic stif fnesses ir, pipe supports and the effects on piping systems.

o Third paragraph introduction et. seq. (CASE Ex. 884).

2.0 Cygno Interpretation Did Cygno evoluote the effects of support stiffnesses on the piping analyses?

3.0 Response in the IAP Draft Report, Cygno questioned the pipe support stiffnesses utilized on Comanche Peak. Note 2 to Checklist PS-01 states

" Pipe Support Stiffnesses "The NRC SIT raised the issue of support stiffness in item 3.j of the above referenced reports. Gibbs & Hill has performed a generic study for review by on NRC consultant. The study shows that using I/16" deflection criterio

! - on _ support design provides acceptable stiffnesses for the piping analysis (changes in support stiffness do not greatly offect piping results). The NRC review results were not available at the time of the Cygno review."

l Since the IAP was performed for the NRC Staff, further evoluotion of an issue already identified and reviewed by the Staff would have been redundant. Accordingly, Cygno recorded the potential deficiency on the appropriate checklist and deferred to the Staff evoluotion.

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Comanche Peak ASLB Hearings Response to CASE Questions Question No. Doyle //17 Exhibit No. None 1.0 CASE Question Has Cygna verified the statement: "No 2-inch topping"?

o This offects the calculation for Hiltis relative to embedment, since a non-monolithic shear plane has been established.

2.0 Cygno Interpretation Thccc support drawings within Cygna's scope of review contain a note regarding the 2" topping. These are:

o RH-l-010-002-522S, Rev. 5 o RH-l-024-01 l-S22A, Rev. I o 51-1-038-013-S22A, Rev. 2 On the first two drawings, the note states "No 2-inch topping". On the other drawing, 2 inches of topping is specified.

What credit was taken for this topping in the calculation of minimum expansion anchor embedment?

3.0 Response To verify the adequacy of expansion anchor embedment lengths, Comanche Peak began

! with the full length of the anchor and then subtracted items such as the plate thickness, thread length, grouting and topping. Therefore, in calculating minimum embedment length, no credit was taken for the strength of the topping.

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Comanche Peak ASLB Hearings Response to CASE Questions Question No. Walsh //4 Exhibit No. None i

1.0 CASE Question )

I PI-02 is there on error in the table shown?

2.0 Cygno interpretation Referring to Observation PI-02-03, Attachment A, is there on error in the calculated table?

3.0 Response There is a typographical error in the calculated table. The allowable for restraint RH-l-064-007-S22R should be "44000", rather than "4400".

As shown on the attached Table, Enclosure W4-1, this correction puts the allowable for the aforementioned restraint into line with the other restraints tabulated.

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. I ENCLOSURE W4-1 Observation

( i i Record Review

"" Attachment A R.vlsion No, g Ch.cklist No. PI.02 Sh..t of

, on..rvation No.PI-02-03 } 3 Y.s No vene on..rvation x Cl...e x Comm.nts 1.0 Root cause Possible misunderstanding of the Gibbs and Hill procedure 2.0 Resolution Using the range for.the 3 rigid restraints, Cygna calculated the following:

Load CYLNCZ General Support Range Stress Stress Total Allow SI-1-032-003-532R 2700 10362 6763 17125 4 RH-1-064-007-522R 1300 5172 5128 10300 44000 RH-1-016-001-532R 8615 11225 9328 20555 44 The remaining 4 restraints are springs or snubbers and have no thermal load. Thus, there is no increase in stress above allowables.

Cygna also noted that the correct method was used for the welded attachments in anchors of Problem 1-70 and in.all supports in Problem 1-69. Based on this, Cygna considers the error isolated. In addition, the RHR system will probably show the largest percentage difference (between maximian load and range), since it has many modes of operation. Thus, Cygna expects the error would have the most impact on this system. As the new calculations show, the impact on design is negligible and the observation is closed.

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Comanche Peak ASLB Hearings Response to CASE Questions Question No. Walsh 66 Exhibit No. None 1.0 CASE Ouestion CTS-00-006 What is the "significant design margin" as shown in the resolution?

2.0 Cygno Interpretation Observation CTS-00-06 states that "... further analyses by Gibbs & Hill (see Cygna '

Technical File i1.2.1.50, pp. 31-69), incorporating Cygno's comments, revealed that sufficient design margin existed to compensate for the increased stress levels." The

" increased stress levels" refer to the potential increase in stress levels due to the items noted in the observation.  ;

Please quantify the design margins.

3.0 Response To demonstrate the adequacy of the relevant design details, Gibbs & Hill performed a .

refined analysis using the NASTRAN Code. Their analysis showed that more than a 6% _

design margin existed. Considered alone, a 6% design margin is certainly " sufficient." In i addition, it is important to note that the refined analysis was performed using tray weights of 35 lbs./ft.2, whereas the octual troy weight is 28 lbs./ft.2. That represents a 25% margin in the opplied tray weight.

l in total, there is clearly sufficient evidence to conclude that the design is adequate.

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