ML20090A974
| ML20090A974 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 03/17/1981 |
| From: | Knight J Office of Nuclear Reactor Regulation |
| To: | Tedesco R Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML17198A223 | List:
|
| References | |
| CON-BOX-13, FOIA-84-96 NUDOCS 8103260320 | |
| Download: ML20090A974 (7) | |
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i Docket No.: 50-329/330 N
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MEMORANDUM FOR: Robert L. Tedesco, Assistant Director for Licensing. DL 4
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FROM:
James P. Knight. Assistant Director for
'67 Components & Stnictures. DE wa, asD**r
SUBJECT:
RESPONSES TO CONStMER$'. POWER FIRST SET OF s.
INTERR0GATORIES FROM THE MECHANICAL ENGINEERING BRANCH (MIDLANDSETTLEMENTISSUE)
N Find enclosed input from the MEB responding to. the first set of interro-gatories issued by Consumers Power concerning soil settlerent dated November 17, 1980. These responses are primarily concerned with buried piping and were prepared by A. J. Cappucci with technical assistance from ETEC. Drafts of these responses were provided to Dave Hood of your staff to assist him in meeting the deadlines set by the ASLB.
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. James P. Knight, Assistant Director for Components a Structures Division of Engineering i
Enclosure:
As stated cc w/o enc 1:
R. Vollmer W. Patton cc w/ enc 1:
R. Bosnak i
H. Branner l
F. Cherny D. Hood H. Levin L. Auge. ETEC F. Rinaldi J. Kane R. Gonzales D. Gupta f'
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Responses to Consumers' First Set of Interrogatories Not applicable.
he 50.54(f) questions 17 thru 20 were directed to acceptance criteria.
The portions of these questions so directed are:
(a) 50.54(f) question 17 - A portion of this question concerning the assurance of code allowable conditions and proper remedial action.
(b) 50.54(f) question 18 - All of this question related to acceptance criteria.
(c) 50.54(f) question 19 - A portion of this question requires defining acceptance criteria for excesssive deformations.
(d) 50.54(f) question 20 - All of this question related to acceptance criteria.
The acceptance. criteria coupled with the details of the remedial action is necessary to evaluate the technical adequacy and proper implementation of the proposed action. The acceptance criteria from ASME Section III, AWWA or some other defined acceptance criteria is required to determine whether or not the piping in question will perform its. intended function. That is to maintain its pressure boundary integrity and allow unrestricted design flow.
If the piping does not meet its defined acceptance criteria, then remedial
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action must take place, this could mean further analysis or repair such as rebedding the piping. The staff must have. conf.idence that the remedial action will either demonstrate that the piping can perform its intended function or return the piping to a physical state where its performance is assured. Therefore, the-staff-must--evaluate-the proposed actions._____
In the responses to the 50.54(f) questions (17 thru 19) acceptance criteria and the basis for this criteria was either non-existant or weakly presented.
Specifically:
(a) There was no commitment to use.the 3.0S limit of NC-3652.3 of ASME Section III, Division 1.
However,intEble17-2oftheresponsesto the 50.54(f) questions there is an indication that the code calculations were used.
(b)
In terms of seismic category I piping between structures references are made to applicable codes, however, there was no indication as to which codes or what specific acceptance criteria the piping would meet.
(c) There was no basis for selection criteria for determining which piping i
would be profiled.
Up and until December 6,1979, each item the staff requested with reguard to acceptance criteria with reference to seismic category I piping is listed below.
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l (a)
In 50.54(f) question 17 the staff requested acceptance criteria for meeting code allowables.
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W-q, (b) Again, in 50.54(f) question 18 the staff requested acceptance criteria concerning compliance with the code allowables.
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(c)
In 50.54(f) question 19 acceptance criteria was requested defining i
excessive deformation.
(d)
In 50.54(f) question 20 acceptance criteria was required to define acceptable loads on components and supports produced by pipe deformations due to settlement.
6.
-Sa 50.54(f) question 17 yes response to 50.54(f) question 17, revision 2, 7/79 p
no if
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(f) There was not comitment to use 3.05 criteria of the ASME' Code, only an indication that it was compafed with the actual stresses due to settlement for illustrative purposes.
(g)
R. Stephens/A. Cappucci & MEB/NRR
-5b a 50.54(f) question 18 b
yes c
responses to 50.54(f) questions 18, revision 2, 7/79 1
d no 1
e 1/
f) There was no detailed description of the acceptance criteria; provided only that they would comply with the applicable codes.
More details as to the stress limits used would be required.
(g)
R. Stephens/A. Cappucci D MEB/NRR
-Sc a) 50.54(f) question 19
)I yes response to 50.54(f) question 19, revision 2, 7/79 h not determined prior-to 6-79
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j j The adequacy of the acceptance criteria for determining the acceptable deformation limits was under review pending the results of the surcharge program' R. Stephens/A. Cappucci -> MEB/NRR 1/.
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-5d T0.54(f) question 20 yes i
. responses to 50.54(f) question 20, revision 2, 7/79 no 1/
To acceptance criteria was defined, only a statement that there j
was an indication that the loads on components were within.the allowables.
(g)
R. Stephens/A. Cappucci @ MEB/NRR t
7.
Each item of ac'ceptance criteria the staff. requested after December 6, 1979 is listed below. This information was requested by ETEC and subsequently transmitted by the staff after review.
l (a) The criteria which addresses pipe buckling.
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(b) The criteria for the selection of piping to be profiled.
(c) The criteria for the change in piping curvature.
1/ Enclosure 3 to "Sumary of January 16, 1980 Meeting on Supplementhi Requests Regarding Plant Fill," dated February 4,1980.
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7a(a) Document given at a meeting between Consumers' Power and NRC on January 16, 1980 yes j
in response to questions 17 & 34, revision 5 no conference call on 9/8/80 The criteria does not consider the local buckling or crippling stresses due to high bending stresses in the large diameter thin walled piping.
The buckling stresses due to earth loads, vehicular and railroad traffic, etc. are based on uniform soil properties. From the pipe profiles it is apparent that this is not the case.
(g)
A. Cappucci, MEB/J. Brammer, ETEC f
7b a see7a(a)above
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yes c
responseto50.54(f) question 17, revision 5 d
no (e
conference call on 9/8/80 (f) There was not sufficient information as to the total piping involved.
the proximity of the non-profiled to the profiled piping, the percentage of piping profiled, soil characteristics in the area of concern, etc.
Due to changes in slope of some of the profiled piping.
it would then appear that the soil characteristics vary.
(g)
A. Cappucci, MEB/J. Bramer, ETEC 7c a see 7a(a) abo'e v
b no none not applicable not applicable i
The rate of change on the slope or the radius of curvature of the piping determines the' bending stress more than the overall deflection.
This request was made~on that basis; If a ~ satisfactory. allowable-stress and strain criteria is presented with an acceptable stress analysis, the criteria for the changein piping curvature would not be required.
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(g)
A. Cappucci, MEB/J. Bramer, ETEC It should also be noted that ETEC had concerns about the small piping associated with.the Diesel Generators. The diesel fuel lines in particular.
ETEC requested acceptance criteria for compliance with the Code for these line.s.
A. J..Cappucci' determined that Consumer's original discussion of these lines was acceptable.
9.
(a) That all the Seismic Category I piping be profiled.
(b) That remedial action'be specified if stresses due to settlement approached or were beyond the code allowables.
(c) That details as to the' calculational schemes and assucptions for.
determining stresses due to settlement and other combined loads be submitted and reviewed..
(d) That the results of the analysis of nozzle. loads be submitted.
l (e) That a monitoring program be establi::hed ovei the life time of the plant to monitor future settlements.
(f) That future settlements be included in the presented analysis.
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9a'(a yes (b
50.54(f) question 17 (c
responseto50.54(f) question 17, revision 2 (d
no (e
unknown (f
The criteria for selection of the piping to be. profiled appears to be based on the soil in the same per;ximity as being homogeneous.
There is no evidence that this i: the case.
(g)
R. Stephens/A. Cappucci > MEB/NRR 9b(a) yes (b
50.54(f) question 17 c
response to 50.54(f) question 17, revision 2
.d no e
unknown f
The response to 50.54(f) question 17 stated that the r. tresses due to settlement would be well below the code allowables as indicated in table 17-2. Therefore, it was indicated that remedial action was not planned. This was not responsive because (1) all piping was not profiled (2) future settlements had not been predicted and (3) the results of the surcharge program had not been established.
(g)
R. Stephens/A. Cappucci > MEB/NRR 9c(a nd (b, (c), (d) and (f) - not applicable (g
R. Stephens/A. Cappucci P MEB/NRR 9d(a) no (b), (c), (d) and (f) - not applicable (g)
R. Stephens/A. Cappucci y MEB/NRR 9e(a) yes (b) 50.54(f), question 18 (c) response to 50.54(f) questioii18, revisiori 2
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(d) no (e) unknown (f) The response to the above question (9e(c)). indicated no plans for a monitoring program if the settlements remain within the predicted range.
I was not clear as to the time frame and methods for verifying the predicted ranges.
(g)
R. Stephens/A. Cappucci => MEB/NRR 9f a yes b 50.54(f( questions 17, 18 and D c
responses to 50.54(f) questions 17, 18 and 19, revision 2 no unknown responseto50.54(f)17-noinformationastothesettlementsover the lifetime of the plant / response to 50.54(f) 18 - adequate / response to 50.54(f) 19 - no information as to the predicted deformations
- 11. The following is a list of information the staff will require to conclude that the safety issues associated with remedial action to be.taken to correct soil deficiencies with requard to underground piping will be resolved. This list does not include responses to interrogatory 7.
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, (a) A final stress analysis of the Seismic Citegory I piping.
(b) An explanation for the relatively rapid changes in some of the piping profiles and the magnitude of the loads which cause these changes.
(c) The actual and predicted clearances after 40 years of Seismic Category I piping at building penetrations.
(d) The loads and stresses on the piping at their termination points (anchors, equipment,largerpipe,etc.).
(e) From the January 20, 1981 meeting provide method and basis for normalizing the profile data prio.r to performing the stress analysis and used of 3" inch future settlement data.
If a non-linear analysis is to'be per-formed provide the analysis methodology with a summary of the results.
Include a presentation of the margin to the Code allowable for settle-ment only and the same for the margin to failure considering all primary and secondary stresses.
12.
llaa) yes b) letter from Robert L. Tedesco to Mr. J. W. Cook dated October 20, 1980.
c) letter from J. W. Cook to R. l.. Tedesco dated November 14, 1980 including a document entitled, " Summary of Settlement Stress Calculations for Buried Piping".
(d) no (e) conference call on January 14, 1981 (f) The Bechtel Stress Analysis appeared to be unconservative and did not give a true representation of the actual stresses in the piping.
There were questions as to which profiles were used and the, justification for the boundary conditions assumed. An ETEC stress analysis demonstrated much higher stresses than the Bechtel report.
It should also be.noted that at the January 20, 1981 meeting Bechtel stated that subsequent ~enalysis had shown much-higher stresses-for certain-lines.
(g)
A. Cappucci, MEB/J. Bramer, ETEC lib,c&d(a yes (b
meeting of January 20, 1981 Consumers' has not responded.to these requests (g
A. Cappucci, MEB/J. Bramer, ETEC lle(a) No.
After the January 20, 1981 meeting a preliminary response to I
Consumers' presentation and questions was drafted and sent to the Project Mana er (D. Hood).
(b), (c), (d), (e, (f) - Not applicable.
l (g)
A. Cappucci, MEB/ J. Brammer, ETEC l.
13)
Consumers' Power Company has submitted the fol. lowing acceptance criteria l
concerning the stresses and deflection of the buried piping due to ground settlement.
- 1) The stresses will meet the ASME Section III, Division I, Subsection NC, Equation 10a Code requirement (3Sc).
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2') AWWA critcria concerning the allowable radial deflections of buried piping.
- 14. Consumers' has submitted sufficient information on the criteria identified in the response to interrogatory 13 to justify each acceptance criteria if in fact they meet it.
- 15. Other than the criteria listed in reponse to interrogatory 13, neither ETEC or the MEB has knowledge of any other criteria which Consumers' has supplied concerning buried piping.
- 16. See the response to interrogatory 15.
17.
Not applicable.
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