ML20115H010
| ML20115H010 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/20/1992 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| IEB-88-008, IEB-88-8, TXX-92500, NUDOCS 9210260407 | |
| Download: ML20115H010 (7) | |
Text
_ _ . _ _ _-__ _ .
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Log i TXX-92500 i
File # 10119
= 903.6 illELECTRIC R' ' " * ~**
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October 20, 1992 Guvp t we l'1whar U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.. C. 20555 I
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) - UNITS 1 AND 2 DOCKET NOS. 50-445 AND 50-446 SUPPLEMENTAL RESPONSE FOR UNIT 1 AND INTERIM RESPONSE FOR UNIT 2 TO NRC BULLETIN 88-08: THERMAL STRESSES IN PIPING CONNECTEC TO REACTOR COOLANT SYSTEMS
. REF: 1) Supplement No. 25 to NUREG-0797 Related to Operation of the Comanche Peak Steam Electric Station, Unit 2 (September 1992)
- 2) HRC Letter from Thomas A. Bergman to William J. Cahill, Jr.,
dated September 17, 1992 Gentlemen:
NRC Bulletin 88-08 was issued by the NRC on June 22, 1988. It contained two reporting requirements applicable to CPSES. The TV Electric letters listed below are included as enclosures (cover letters only, attachments /
enclosures to previous letters are not included). TV Electric's response to Reporting Requirement 1 of NRC Bulletin 88-08 was provided by:
o TU Electric letter logged TXX-88766, from W. G. Counsil to NRC, dated October 31, 1988 (Units 1 and 2)
TV Electric's response to Reporting Requirement 2 of HRC Bulletin 88-08 was provi6ed t,y:
o TU Electric letter logged TXX-89805, from William J. Cahill, Jr.
to NRC, dated November 17, 1989 (Interim Response, Units 1 and 2) o TU Electric letter logged TXX-90113, from William J. Cahill, Jr.
to NRC, dated March 27, 1990 (Final Response, Unit 1) o TU Electric letter logged TXX-92010, from William J. Cahill, Jr.
to NRC, dated February 7, 1992 (Update Final Response. Unit 1) 260058 1
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l 4 4 TXX-92500 Page 2 of 4 The purpose for this letter is to update lu Electric's response for Action 3 of Reporting Requirement 2 for Units 1 and 2, and to retffirm the schedule for completing Action 2 and 3 of Reporting Requirement 2 for Unit
- 2. For clarity, Reporting Requirement 2 and associated Action 3 have been restated. The attachment provides the required affidavit, in accordance with the requirement of HRC Bulletin 88-08, that responses be submitted under oath or affirmation 'Jnder the provisions of Section 182a, Atomic Energy Act of 1954, as amended.
Reportino Reauirement 2 Those addressees who determine that there are unisolable sections of piping that can be subjected to . tresses from temperature oscillations that could be induced by leaking valves and that were not evaluated in the design analysis of the piping shall submit a letter within 30 days of completion of Actions 2 and 3. This letter should confirm that Actions 2 and 3 have been completed and describe the actions taken.
Action 3 Plan and implement a program to provide continuing assurance that unisolable sections of all piping connected to the RCS will not be subjected to combined cyclic and static thermal and other stresses that could cause fatigue failure during the remaining life of the unit. This assurance may u*e provided by 1) redesigning and modifying these sections of piping to withstand combined stresses caused by various loads including temporal and spatial distributions of temperature resulting from leakage across valve seats, 2) instrumenting this piping to detect adverse temperature distributions, or 3) providing means for ensuring that pressure upstream from block valves which might leak is monitored and does not exceed RCS pressure.
.TU Electric Response to Action 3 Unit 1:
TV Electric has implemented a program utilizing the second option described by Actior 3 above. Resistance Temperature Detectors (RTDs) have been installed on the unisolable piping sections described in:
o TU Electric letter logged 1XX-88766, from W. G. Counsil to NRC. dated October- 31, 1988 The RTDs sense pipe temperatures at selected locations on the piping.
The output of these RTDs is fed to a data acquisition system.
Temperature data is collected by Operations personnel at procedurally specified-intervals and is used to develop temperature profiles for evaluation by engineeriy personnel.- Other plant parameters, such as RCS pressures and temperatures, and system flow rates are also recorded.
t
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TXX-92500 Page 3 of 4 Limits on temperatures and differential temperatures are specified in procedures. If these limits are exceeded, further engineering evaluations are conducted and appropriate actions taken. The above program is based on monitoring guidelines developed by Westinghouse.
Installation of the RTDs, Data Acquisition Systet, and interconnecting wiring has been completed. Data Acquisition System testing and checkout was performed and the system was declared operational on March 10, 1990.
Documentation of these activities is available for review by NRC inspectors.
To address the phenomena described in NRC Bulletin 88-08 Supplement 3 TV Electric submitted the following:
o TV Electric letter logged TXX-89246, from William J. Cahill, Jr.
to NRC, dated May 9, 1989 (Analysis of Unit 1 Residual Heat Removal (RHR) lines) o TV Electric letter logged TXX-89566, from William J. Cahill, Jr.
to NRC, dated August 9, 1989 (Supplemental evaluation of Unit 1 RHR lines and overview of monitoring program for RHR lines, including RTDs) o TV Electric letter logged TXX-89710, from William J. Cahill, Jr.
to RC, dated September 18, 1989 (SupplementalevaluationofUnit1RHRtoaddressNRCconcerns)
TV Electric subsequently requested that the requirement to record data be suspended and that an augmented Inservice Inspection (ISI) program be used to satisfy the prc lisions of Action J of NRC Bulletin P8-08. These requests were documented by the following:
o TV Electric letter logged TXX-92010,.from William J. Cahill, Jr.
to NRC, dated February 7, 1992 (Request suspension of requirement to record data for Unit 1) o TU Electric. letter logged TXX-92078, from William J. Cahill, Jr.
to NRC, dated February 24, 1992 (Analyses of' thermal stresses in the Unit 2 RCS branch lines) o TV Electric letter logged TXX-92009, from William J. Cahill, Jr.
to NRC, dated March 23, 1992 (Supplemental evaluation of Unit 1 RHR lines thermal stratification)
In response to the above requests, the NRC notified TV Electric by References 1 and 2 that an augmented ISI program is not an accepi;able meant for satisfying the requirements of Action 3 of NRC' Bulletin 88-08. ,
e TXX-92500 Page 4 of 4 Instead of implementing an augmented ISI program TV Electric will continue to record data for Unit 1 as described by:
o TV Elect /ic letter logged TXX-89566, from William J. Cahill, Jr.
to NRC, dated August 9, 1989 (Supplemental evaluation of Unit 1 RHR lines and overview of monitoring program for RHR lines, including RTDs) o TV Electric letter logged TXX-89710, from William J. Cahill, Jr.
to NRC, dated September 18, 1989 (Supplemental evaluation of Unit 1 RHR to address NRC concerns) o TU Electric letter logged TXX-90113, from William J. Cahill, Jr.
to NRC, dated March 27, 1990 (FinalResponse, Unit 1)
The Unit 1 program for data collection and evaluation uses the guidelines of Appendix EE, Section 4.0, item (3), of Reference 1. A similar program will be implemented for Unit 2 prior to Unit 2 fuel load.
As required by NRC Bulletin 08-08, Actions 2 and 3 will be completed for Unit 2 prior to Unit 2 initial criticality, and a letter will be submitted pursuant to Reporting Requirement 2 within 30 days of completing Actions 2 and 3.
Sincerely, -
}
- lA fv[-
William J. Cahill, Jr.
' CBC/vid Attachment Enclosure c - Mr. J. L. Milhoan, Region IV Residentinspectors,CPSES(2)
Mr. T. A. Bergman, NRR Mr. B. E. Holian, NRR I
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Attachment to TXX-92500 Page 1 of 1 UNITED STATES OF D: ERICA NUCLEAR REGULATORY COMMISSION In the Matter of Texas Utilities Electric Company Docket Nos. 50-445 and 50-446 (Comanche Peak Steam Electric Station, Ur<its 1 & 2)
AFFIDAVIT William J. Cahill, Jr. being duly sworn, hereby deposes and says that he is Group Vice President, Nuclear of TU Electric, the lead Applicant herein; that he is duly authorized to sign and file with the Nuclear Regulatory Commission this response to NRC Bulletin 88-08 for the captioned facility; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief.
$j ___ A William J. Cahili, Jr.
Group Vice President, Nuclear STATE OF TEXAS -
COUNTY OF SchWVFLL Subscribed and sworn to before me, on this 19th day of october ,
1992. ,
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Notary Public Agw ,
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- FATmCIAMLSON h(k:h L p uv canosi tems March 16,1993 L-Qi,"gj s.
t Attachment to TXX-92500 Page 1 of 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY-COMMISSION In the Matter of Texas Utilities Electric Company Docket Nos. 50-445 and 50-446 (Comanche Peak Steam Electric Station, Units 1 & 2)
AFFIDAVIT William J. Cahill,'Jr. being duly sworn l'etreby deposes and says that he is.
Group Vice President, Nuclear of TV Electric.-the lead Applicant herein; that he is duly authorized to sign and file with the Nuclear Regulatory Commission this response to NRC Bulletin 88-08 for the captioned facility; that he is familiar-with the content thereof; and1that the matters- set' forth therein are true and correct to the best of his knowledge, information and belief.
' /.
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A William.J. CahilT. Jr.
Group Vice President, Nuclear STATE OF TEXAS )
)
COUNTY OF SOMERVELI. )
Subscribed and sworn to before me,-on this 19th day of october ,
1992.
Notary Public-
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PATRICIA WILSON .
w emwa twa
- r;gp - . IAVI.h 16,1993.
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4 Enclosure to TXX-92499 (20 pages total, including this page) o TV Eleciric letter logged TXX 88766, f rom W. G. Counsil to NRC, dated October 31, 1988 o 10 Electric letter logged TXX 89246, from William J. Cahill, Jr.
to NRC, dated May 9, 1989 (Analysis of Unit 1 Residual Heat Removal (RHR) lines) o TO Electric letter logged TXX 89566, f rom William J. Cahill,' Jr.
to NRC, dated August 9, 1989 (Supplemental evaluation of Unit 1 RHR lines and overview of monitoring program for RHR lines, including RTOs) o TV Electric letter logged TXX-89710, f rom William J. Cahill, Jr.
to NRC, dated September- 18, 1989 _
(Surplemental evaluation of Unit 1 RHR-to address NRC concerns) o 10 Electric letter logged TXX-89805, from William J. Cahill.- Jr.
tt 'RC, dated November 17, 1989 (Interim Response Units 1 and 2)-
o TV Electric letter logged TXX 90113, from William J. Cahill, Jr.
to NRC,. dated March 27, 1990 (final Response. Unit 1) o TV Electric letter logged TXX 92010 from William J. 'Cahill, Jr.
to NRC,' dated February 7, 1992 (Update. Final Response-for Unit 1, request suspension of requirement to record data) o TV Electric letter logged TXX 92078, from William J. Cahill, Jr.
to NRC, dated Febreary 24, 1992
( Analyses of thermal stresses in the Unit 2 RCS branch lines) o TV Electric letter logged TXX-92009, from~ William J. Cahill, Jr.
to NRC, dated March 23, 1992 (Supplemental evaluation of Unit 1 RHR lines thermal stratification) d a
____m_ .___. _ _ _ _ _ . _ - - - - - - - - - - - - - -
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' Log a Txx-88760
-- 2 File # 10119
? ~f Ref. # NRCB 88-08 TUEllCTRIC October 31, 1o88
%!!!!am G. counMI tien.sne I we PernJen:
U. S. haclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 2.0555
" St'0.J C T : COMANCHE PEAK STEAM ELEC 71C STATION (CPSES)
.s 4 DOCKET N05, 50-445 AND 50-446 p
NRC BULLETIN 88-08: THERMAL STDESSES IN g PIPING CONNECTED TO REACTOR COOLANT SYSTEMS Gentiertn.
On October 21, 1988, TU Electric letter logged TXX-88740 responded to Action 1 of NRC Bulletin 88-08, " Thermal Stresses in Piping Connected to ,
Reactor Coolant Systems." Reporting requirements of NRC Sulletin 68-08 required tnat the responses be submitted under oath or affirmation under the provisions Sf Section 182a, Atomic Energy Act of 1954, as amerded. s TXX-88740 did not provide TV Electric's response to Action 1 t " cath or affirnation as required by MC ~ Bulletin 88-08. TU Electric's 4 snse to Bulletin 38-08 Ac , 1 is hereby ren'bmitted under oath. "
TV Electric has c ' eted a ree mw o' m ,licable systems connectec' to the Reactor Coolant Systems (RCS) os rt:4 u ' n-' Sy Action 1 of the bulletin. TV Electric has identified unisolable so. uns of piping connected to the RCS
. mv be subjected to stresses from temper &ture stratification or vrature oscillations that could be induced by leaking valves and were not eutuated in the design analysis of the piping. The 1.nes that may bt affected by these types of thermal stresses are:
- 1. charging line downstream of valve 8146,
- 2. alternate charging line downstream of valve 8197, s 3. auxilicry spray line downstream of valve 8145, and 4 four centrifugal charging pump cold leg injection lines downstream of valves 8801A/8801B, In addition, we are aware of the phenomenon cited in footnote-1 of this bulletin, and Information Notice 88-80 related to the p".ential for thermal stratitication in the pressurizer surge line as a r< ;uit of a temperature difference betwecn the pressurizer and the RCS hot leg during heatup and cooldown sequences. Since this potential thermal stratif b tion would not be the resu?I of leaking valves and therefore not within the scope of this bulletin, this issue is being addressed indepenaently of the actions required by this bulletin,
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TXX-88766 l Page 2 of 2 4
October 31, 1986 '
4 Actions 2 and 3 will be completed prier to criticality of the respective CpSES i unit. TU Electric will submit a letter describing the actions taken within 30 4
days of completion of Actions 2 and 3 for each CPSES unit.
l Very truly yours,
{ '/b}$
- W. G. Counsil
- j. HAM /gj
- attachment i
! c Mr. R. D. Martin, Region IV
- Resident inspectors, CPSES (3) l 4
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""' 7 Log i TXX-89246 C
File # 903.6 C Ref. # 10CFR2.790
- nlELECTRIC May 9, 1989 W.J.Caha o m.,,,,vr,e m s . -
]
U. S. N0clerr Regulatory Commission Attn: Document Control'0esk
- Washington, D. C. 20S55 2
SUBJECT:
COMANCHE PEAN. STEAM ELECTRIC STATION (CPSES) 00C<ET NO. ".0-445 ANALYSES G: THERMAL STRESSES AND LEAK-BEF0"E-BREAK.
QUALIFICATION FOR THE RESIOUAL HEAT REMOVAL LINES REF:
TU Electric Le'ter (TXX-8t 1) from William J. Cthill,- Jr.
te the NRC dated May 1, 1989 Gentlemen:
i The above reference-responded to Action 2a of NRC Bulletin 88-11, "Presserizer
< Surge Line Therm +1 Stratification" and provided analyses in support of leak-before-break qualification for the. CPSES Un,it 1 Pressurizer Surge Line, in addition, TV Electric indicated that the issue of potential thermal stratification effects and leak-before-break qualification for the CPSES Unit May 9, 1ResidualHeatReuioval(RHR) 1989. suction.lineswouldbe..submittedby 4 TU Electric has completed analyses of the potential effects of
' thermal stratification on the CPSES Unit 1 RHR suction lines. The analyses show that thermal stratification will not affect the integrity of the RHR suction lines or the ability to satisfy leak-before-break criteria. These analyses encompass.the phenomena described in NRC Bulletin 88-08 Supplement 3,
" Thermal Stresses In Piping Connected To Reactor Coolant Systems."
Additional analyses were performed ti, address N concerns that the RHR
- uction lines are acceptable candidates for arplication of leak-be are-break methodology. -This letter provides the ' analyses in the enclosed documents.
The first enclosure consists of five (5) copies of WCAP-12258 entitled
" Evaluation Heat Removal of thermal
'.iaes" Stratification (Proprietary) . for the Comenche Peak Unit 1 Residua l
l 400 Norn Obve Saeer LB 81 D 4an, Tesan73201-b $ jfS 0 0 S J U
. Hay 9, 1989 Page 2 of 2 The second enclosure consists of five (5) copies of WCAP-12259, entitled
" Evaluation of Thennal Stratification for the Comanche Peak Unit 1 Residual Heat Removal Lines" (Non-Proprietary). ,
The third enclosure consists of a Westinghouse Application for Withholding, CAW-89-064, Accompanying Af fidavit, CAW-88-129, and Proprietary Information -
Notice.
This submittal contains information proprietary to Westinghouse Electric -
Corpc ra t io'1, it is supported by an affidavit-signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the~
information may be ~ withheld from public disclosure by the Commission ond.
addresse,s with specificity the considerations listed in paragraph.(b)(4) of 10CFR2.790.
Accordingly,.it is. respectfully requested that the information which-is proprietaryLto Westinghouse be withheld from public disclosure in accordance with 10CFR2.790. . Corresaondence with respect to ?he proprietary aspects of-the Application for With1olding should-reference CAW-89-064 or the supporting Westinghouse affidavit, CAW-88-129. and be addressed to R. A. Wiesemann, Manager Regulatory and Legislative Affairs, Westi_nghouse Electric Corporation, P.O. Box 355, Pittsburgh, Pennsylvania 15230.
Sincerely, WilliamJ.Cfhill,'Jr.
Byi lNF M ~
D. R. W6odlan-Docket Licensing Manager
- HAM /vid-
- Enclosures i c - Mr. R. D. Martin, Region IV w/o enci Resident Inspcctors, (CPSES) (3) w/o enci l
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.E N Log i TXX 89566 1 .-- File # 903.6
- .
- :: ::: 10005 (clo)
! ygggggq77j7g7 Ref. # 10CFR2.790.
August 9, 1989 ,
Waana J. Cahm. Jr.
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U. S. Nuclear Reg 11atory Commission Attn: Doctment Control Desk Washington D. C. 20555 3
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
' DOCKET NOS. 50 445 AND 50 446.
SUPPLEMENTAL EVALUATION OF RESIDUAL HEAT REMOVAL
{ (RHR) LINES THERMAL STRAT!FICATION AND LEAK-8EFORE-
- BREAK QUALIFICATION FOR THE COMANCHE PEAK UNIT 1 l REF
- TV Electric Letter (TXX-89246) free Willia? J. Cahill, Jr. to the NRC dated May 9, 1989 Gentlemen:
! A public meeting was held on July 27, 1989 at the NRC office earng-representatives of the NRC,-TV Electric, and Westinghouse to~ discuss TU Electric's plan to submit a supplement to the evaluation transmitted by the above referenced letter. The supplemental'evaldation desor.strates that the RHR piping integrity will be maintained during niant operation and that l
the leak befors break criteria are satisfied;~"The supplemental ~ evaluation '
concludes that the piping complies with the ASME !!! Code and presents a
> comprehensive monitoring program to cc ifire the analyses contained therein.
This letter provides the supplemental evaluation and monitoring program administrative details in a total of ont attachment and three enclosures, i The presentation slides used in the July 27, 1989 public. netting are provided as an appendix to enclosures one and two. Durirg the finalization of.the monttoring progres details the frequency for collection of data during critical periods was changed from two minutes, as presented in the a
July 27. 1989 public meeting, to three minutes to facilitate data coliection
! automation.
,. The attachment.provides en overview of the manner in which the monitoring li progree is to be sadScted and administrative measures taken to address issues crising fro. w,e menitoring progr3e in a timely manner, The-first enclosure' consists of five (5) copies of WCAP-12258 Supplement 2.
entitled " Evaluation of Thermal Stratification for Comanche Peak Unit 1 Residual Heat Removal Lines (RHR)" (Proprietary).
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5 ll TXX 89566 August 9, 1989
- Page 2 of 2 1he second enclosu e consists of five (5) copies of WCAP 12259 Supplement 2, entitled " Evaluation of Thermal Stratification for Comanche Peak Unit 1 Residual Heat Removal Lines (RHR)" (Non Proprietary).
The third enclosure consists of a Westinghouse Application for Withholting, CAW 89 91, Accompanying Affidavit, CAW 88 129, and Proprietary Information Notice.
As this submittal contains information proprietary to Westinghouse Electric Corporation, it is supported by an affidavit signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the 4 information may be withheld from p1b11c disclosure by the Commission-and addresses with specificity the considerations-listed in parHgraph (b)(4) of 10CFR2.790, i
4 Accordingly, it is respectfully requested that the inforettien which is
, proprietary to Westinghouse be withheld from public disclosure in accordance with 10CFR2.790. Correspondence with respect to the proprietary aspects of the Application for Withholding or the Supporting Westinghoose Affidavit should be addressed to Mr. R. A. Wiesemann, Manager, Regulatory and Legislative Affairs Westinghouse Electric Corporation, P. O. Box 355, Pittsburgh, Pennsylvania 15230.
Sincerely, +
y William J. Cahill, Jr.
i HAM /vid Attachment Enclosures l
) c - Mr. R. D. Martin, Region IV
, Resident Inspectors, CPSES (3) i-
4
+
4 J
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=m- Log- # TXX-89710 File # 903.6
- 1 1- 10005(clo)
C -
Ref. # 10CFR2.790 l
illELECTRIC
! September 18, 1989 O,b.',W$a i
U. S. Nuclear Regulatory Comission Attn: Document Control Desk
- Washington, D. C. 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446
. SUPPLEMENTAL EVALUATION OF RESIDUAL HEAT l- REMOVAL (RHR) LINES THERMAL STRATIFICATTON
- AND LEAK-BEFORE-BREAK (LBB) QUALIFICATIJ REF: 1) TU Electric Letter (TXX-89246) from William J. Cahill, Jr.
! to the NRC dated May 9, 1989
l to the NRC dated August 9, 1989 1
i Gentlemen:
On May 9,1989, TU Electric submitted by reference (1) an evaluation of
- potential thermal stratification effects and leak-before-break qualification ~*
i for the Comanche Peak Unit 1 RHR piping. TU Electric subsequently _ submitted a
- supolemental evaldation by reference. (2), to address NRC concerns, which I
drumstrated that RHR piping integrity will be maintained during plant-operation and that the leak-before-break criteria are satisfied. Reference t
(2) also provided an overview of the RHR monitoring program and administrative controls that ensure issues arising from the monitoring program are addressed in a timely manner.
In a telephone conference on September 6,1989, representatives of the NRC, TU i Electric and Westinghouse discussed concerns pertaining to the timeliness of reporting RHR thermal cycling; *:he sensitivity of monitoring equipment and i the type of welding perfonned at LBB' evaluated critical crack locations. The
, attachment provides the required infonnation to address and resolve those
- concerns.
! Sincerely,
=- /
l William'J. Cahill, Jr.
! HAM /smp j Attachment c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) j$90f & O N l( M Nonh Olive Street 'LB ol Dalbs Texas 73201
6 tog i TXX 89805
.% E - File # 10119 3 3 Ref. # B 88-08 nlELECTRIC w guess J. caha November 17, 1989 r.,,ca, ur e,,, *"
Jr.
U. S. Nuclear Regelatory Commission Attn: Document Control Desk Washington, D. C. 20555
SUBJECT:
' COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS 50-445 AND 50 446 NRC BULLETIN 88 08: INTERIM RESPONSE TO THERMAL i
STRESSES StSTEMS IN P! PING CONNECTED TO RDC10R COOLANT REF:
! TU Electric October letter TX7 88766, W. G. Counsil to N E dated 31, 1988 1
Gentlemen:
The referenced letter provided TV Electric's response to Reporting 3
Requirement Reactor 1 of NRC Coolant Systems." Bulletin 88 08, " Thermal Stresses in Piping of unisolable. piping that are potentially susceptible to theThe TV -<
described by the Bulletin, and confirmed that _ Action 2 (i.e., phen mena subject to excessive thertl stresses) and Action 3 (i.e., programs forNDE continued respective CPSES assurat.ce) units. would be conspleted prior to initial criticality of the completing Actions 2 and 3, a letter describing the action submitted in accordance with Reporting Requirement 2.
interim response to Reporting Requirement 2 for Unit 1.I The attachment providet the required affidavit in accordance with the requirement of NRC Bulletin 88-68 that responses be submitted under oath or affirmation u provisions of Section 182a, Atomic Energy Act of 1954, as amended. i be submitted in accordance with NRC Bulletin 88-08!
For clarity, Reporting Requirement 2 and. Actions 2 and 3 have been restated. ;
Reoortino Reouirement 2 Those addressees who rietermine that there are unisolable section that can be subjected to stresses from temperature stratification or not evaluated in the design analysis of tM piping sha within 30 days of completion of Actions ? and 3.
that Actions 2 and 3 have been completed and describe the actions takenThis .
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- TXX89805L
[ November 17,1981 j Page 2-of-3.
1 i
8.s. tion. 2 For any unisolable _. sections of-pip ng connected to the RCS that' may have been 3 subjected to excessive' thermal: stresses, examine nondestructively-the welds,'
i heat-affected zones and_ high stress locations, including geometric -
- discontinuities, in that piping to provide assurance that there are no- ,
i existing flaws ~. '
, TU ELECTRIC RESPONSE TO ACTION 2 l-Based on a crack initiation and propagation analyses.for Farley Unit 2, -3 L TU Electric and Westinghouse have determined that it is highly _ unlikelylthat a-
- crack.could be initiated by thermal--fatigue during the relatively shnt a:nount1 l ot' time that Unit 1 has been hot. Therefore,:the- nondestructive uannation-l- requirements of Action 2 are not; consider 6d applicable to CPSES Unit:1.
i Action 3 4
!- Plan and implement a-program to provide continuing assurance:that unisol'able.
- sections;of all: piping connectwl to the RCS _will not' be subjected to combined i cyclic and static thermal and other stresses that could cause; fatigue failure
- during the remaining life.of the- unit. This . assurance may be provided by.
<(1) redesigning and modtfying these' sections of piping to withstand' combined "
stresses caused by_ various. loads including' temporal and_ spatial dis.trihtions' _
I of temperature resulting from leakage across valve seats,--(2) instrumenting j this piping to detect adverse temperature distributions-and; establishing
- appropriate limits on'tcaperature d htributions, or f3)-providing means fo'r
- ensuring that pressure upstrwan from block valves unich might leak is
! monitored.and does not exceid RCS pressure.
4 TV ELECTRIC RESPONSE-TO ACTION 3 .
I TU Electric plans to utilize the second option: described by Action 3_ above.
? Resistance. Temperature Detectors-(RTDs)-will,be installed on the four l unisolable piping sections described Lin the referenced letter. The-RTDs will l measure pipe: temperatures at' selected locations'on the piping. Plant parameters such as~ reactor coolant pump status, reactor coolant pressure, and-pressurizer spray status will:also be monitored.<1 Data will.be periodically ev41uated for indications of unacceptable: thermal stratification. -
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4 TXX 89005 November 17,1989 Page 3 of 3 '
The above program is based on TU Electric's understanding of Ir.dustry and A
Owner's group initiatives currently in process to address the concerns of NRC Bulletin 88-08. Preparation of site procedures and installation of hardware in support of the mer.itoring program is currently in progress.
- Sincerely, p
/ .c '
l
- William o. Cah 1, Jr.
HAM /vid Attachment c - Mr. R. D. Martin, Region IV j Resident inspectors, CPSES (3) i
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== Log # TXX-90113 h j File # 10119
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903.6 Ref. # NRCS 88-08 1tlELECTRIC March 27, 1990 l
U. S. huclear Regulatory Commission Attn: Document Control Desk Washingtor., D. C. 20555
SUBJECT:
C0HANCHE PEAK STEAH ELECTRIC STATION (CPSES)
DOCKET P.0S. 50-4/5 AND 50-446 FINAL RESPONSE FOR UNIT 1 TO NRC BULLETIN 88 08: ,
T!iERhAL STRESSES IN PIPING CONNECTED TO REACTOR COOLANT SYSTEMS Ref: 1) TU Electric letter._TNX-88766, from W. G. Counsil to NRC, dated October 31, 1988,
Gentlemen:
Reference 1 provided TV El~ctric's response to Reporting Requirement 1 of NRC Bulletin 88 08 for Units ^1 and 2. 'The TU Clectric response identified
- sections of unisolable piping that ara po'.entially susceptible to the-conditions described in the bulletin. Reference 2 provided an interim response for. Unit i to Reporting Requirener.t 2 of the bulletin. TU' Electric's final response to Reporting Requirement 12 for Unit 1 is provided below. For clarity, Raporting Requirement 2 and associated- Actions 2- and 3-have been restated. The attachment provides'the required affidavit, in accordance with the requirement of NRC Bulletin 88-08, that responses be sabmitted under oath or affirmation under.the provisions of Section 182a, Atomic Energy Act of 1954, as amended.
Reportino Reouirement 2 those addressees who determine that there are unisolaole sections of piping that can be subjected to stresses from temperature stratificatlan or temperature oscillations that could be induced by' leaking valves and that were not (*aluated in the design analysis of the piping shall submit a letter with.r. 30 days of completion (1 Actions 2 and 3. This letter shrui. confirm that Actions 2 and 3 have been completed and describe the actions taken, t-
- K Olive Dallas, Texas 75201
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, TXX-90113 March '7, 1090 Page 2 of 3
. Action 2
- For any unisolaple sections of piping connected to the RCS that may-have been subjected to excessive-thermal stresses, examine nondestructively the
- welds, heat affected zones and high stress locations, including geometric l discontinuities, in chat piping to provide assurance that there are no existing flaws.
! TV Electric Response to_ Action _1 1
Based on crack initiation and propagation analysis for'Farley Unit 2, 3 TU Electr8e and Westinghouse have determined that it is highly unlikely that a crack could be initiated by thermal fatigue during the relatively short amount of time that Unit I has:been hot.- Therefore, toe
- nondertructive examination requirements of Action 2 are not considered applh etle to Unit 1.
Action 3 Plan and implement a prog.am to provide continding assurance that
!- unisolable sections of all piping connected to the RCS will not be i subjected to combined cyclic and static thermal and other stresses that I could cause fatigue failure during the remaining life of the unit. This assurance may be provided by~1) redesigning and modifying these sections of piping to withstand combined stresses. caused by various losds including
- temporal and spatial distrihutionsLof temperature resulting from leakage '
- across valve seats 2) instrumenting this piping to detect adverse i
temperature distributions and establishing appropriate limits on temperature distributions, or 3) providing means for' ensuring that prassurt upstream from block valves which might leak is monitored and does not exceed RCS pressure.
TU Electric Resnonse to Action 3
- TU. Electric has implemented a. program utilizing the second option,
, described by Action 3 above. Resistance Temperature Detectors (RTD's) have been installed on the unisolable piping sections described in
. reference-1), The RTD's sense pipe temperatures at. selected llocati is on 4
the piping. .The output of these RTD's is fed to a data acquisitir system. -Tetperature data is collected by Operations personnel at procedurally specified intervals and is used to develop temperature pr. files for evaluation by engineering personnel. Other plant parameters.
.uch as RCS pressures and temperatures and system flow rotes are also recorded. ,
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Limits'on temperatures and differential temperatures are specified in l procedures. If'these'11mits are exceeded, further engineering evaluations l i will be conducted and appropriate actions will be taken.. The above -)
- program is based on monitoring guf delines developed by- Westinghouse. The >
1 . program may be modified in-the fucure to reflect operational experience.
I accumulated by CPSES and Westinghouse.
I
{ Installation of the RTD's. Data Acquisition System.'and interconnecting
! wiring ha'te been completed. Data Acquisition System testinc ind checkout -
has been performed and the system was- declared operational _ ori Marchi10.
j 1990. Documentatior of these activities is available for review by'NRC
{ inspectors.
I As required by;NRC Gulle'in 88 08 Actions 2 and 3'will be completed for
! Unit 2 prior to Unit 2 initial criticality, and a-letter will be submitted-l pursuant to Reporting _ Requirement 2 within 30. days of completing Actions 2 and i 3.
1 Sincerely, f- 9 i
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. William J. Cahill, Jr.
N '/ 4, HAM /vid 4 i Attachment c - Mr. R. D Martin. Region IV
!' Resident Inspectors CPSES (3) t-1 i
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Log # Txx-92010 4 File L 10119 1 C
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' 903.6 Ref. # NRCB 88-08 TUELECTRIC suni..J.c.wmJr. February 7 1992 Gene Wre presidre U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington D. C. 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) - UNIT 1 DOCKET NO. 50-445 FINAL RESPCNSE FOR JNIT 1 TO NRC BULLE7IN 88 08:
4 THERMAL STRESSES IN PIPING CONNECTED TG REACTOR COOLANT SYSTEMS REF: 1) TV Electric letter logged TXX-88766, from W. G. Counsil to NRC, dated October 31, 1988
- 2) TV Electric letter logged TXy 89805, f rom W. J. Cahill . Jr.
to NRC, dated November 17 1989
'to NRC, dated March 27 1990 Gentlemen:
Reference 1) provided TV Electric's respanse to Reporting Requirement 1 of NRC Bulletin 88 08 for Units 1 and 2. The IJ Electric response identified sections of unisolable pining that are potentially susceptible to the conditior s described in be bulletin. Reference 2) provided an interim response for Unit 1 to Reporting Requirement 2 of the bulletin.
TU Electric's final response to Reporting Requirement 2 for Unit 1 was provided in Reference 3. The purpose of this letter is to update our response for Action 3 of Reporting Requirement 2. For clarity, Reporting Requirement 2 and associated Action 3 have beer restated. The attachment prnvides the required affidavit, in accordance with the requirement of NRC Bulletin 88 08: that responses be submitted under oath or affirmation under the pro'viu ous o'f Section 182a, Atomic Energy Act of 1954, as amended.
Peportina 9ecuirement_1 Those addressees who determine that there are unisviable sections of piping that ca; be subjected to stresses from temperature oscillatinos that cou!d be induced by leaking valves and that were not evaluated in the Jesign 7 analysis of the piping shall submit a letter within 30 days of completion of Attions 2 and 3. This letter should cor. firm that Actions 2 and 3 have been completed and describe the actions taken.
,r 4 *) A > .n 1 On /- ?- -C [y42fO, 400 N. Olive Secet LB. 81 Dallas. Texas 7520; q v
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TXX 92010 Page 2 of 2 Action 1 Plan and implement a program to provide continuing assurance that unisclable sections of all piping connected to tne RUS will not be subjected to combined cyclic and ,tatic thermal and cther stresses that could cause fatigue failure during the remaining life of the unit. This assurance may be provided by 1) redesigning and modifying these sections of piping to withstand combined stresses caused by various loads inc'.uding temporal and spatial distr.outions of temperature resulting from leakage across valve seats, 2) instrumenting this piping to detect adverse temperature distributions, or 3) providing means for ensuring that pressure upstream from block valves which might leak is monitored and does not exceed RCS pressure.
E'_U ect ric Rescorse to Action 3 TV Electric has implementsd a program utilizing the second option described by Action 3 above. Resistance Temperature Detectors (RTDs) have been installed on the unisolable piping section described in reference 1. The RTDs sense pipe temperatures at selected locatinns on the piping. The '
output of these RTDs is fed to a data acquisition system. Temperature data is collected by Operations personnel at procedurally specified intervals and is used to develop temperature profiles for evaluation by engineering personnel.
Other plant parameters, such as RCS pressures and temperatures, and system flow rates are also recordeds limits on temperatures ano differential tempera *ures are speci'fied in "
procedures.
If these limits are e 40eded, further engineering evaluations will be condk.ted and appropriate actions will be taken. The above program is based on monitoring guidelines developed by Westinghouse. Installation of the RTDs Data Acquisition System, and interconnecting wiring were completed. Data Acquisition System testing and checkout was
"* formed and the system was declared operational on March 10 1990. Decumentation of these 3ctivittei is available for review by NRC inspectors.
g As a result of the analysis performed by Westinghouse and summarized in the enclosure, further collection of data is not necessary. Therefore, we reouest that the requirement to record data be suspended.
Sincerely,
/ r^- ,
William d. Cahill, Jr.
CEJ/vid Attachment Enclosure c - fir. R. D. Martin, Region IV Resident Inspectors CPSES (2)
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- "ll""" "' Log # Txx-92076
- 1. .: File # 903.6
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. . _ :"_ Ref. # 10CFR2.790 1UELECTRIC February 24 1992 William J. Cahlit, Jr.
Grosq Ver ?mwe U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555
SUBJECT:
COMANCHE PEAK STEAP ELECTRIC STATION (CFSES) - UNIT 2 DOCKET N0. 50 446 ANALYSES OF THERMAL STRESSES IN THE RCS BRANCH LINES Gentlemen:
TV Electric indicated that the issue of potential thermal stratification ef fects for the CPSES Unit 2 RCS Branch lines would be submitted before Unit 2 initial criticality. TV Electric has completed analyses of the potential effects of thermal stratification on the CPSES Unit 2 RCS Branch lines. The analyses shov C -- ..ermal stratification will not affect the integrity of these branch li"e2 and that the requirements of NRC Bulletin 88-08 are satisfied.
The first enclosure onsists of five (5) copies of WCAP I3211. titled "NRC
_ Bulletin. 88-08 Ev-lo tion of . Auxiliary Piping for Comanche Peak Vait 2' ,
( P rop ri eta ry ) .
The second enclosure consists of five (5) copies of WCAP-13218, titled *NRC Bulletin 88-08 Evaluation of Auxiliary Piping for Comanche Peak Unit 2" ( Non-Proprieta ry) .
The third enclosure consists of a Westinghouse App'ication for Withholding Proprieary Information with Accompanying Affidavit CAW 92-269, Propris.ary information Notice and Copyright Notice.
This submittal contains information proprietary to Westinghouse Electric Corporation, it is supported by ar. affidavit signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (t)(4) of 10CFR2.790.
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E N. OUve street LB. 81 Dallas. Texas 73201 3 ON [ h.
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Accordingly, it it respectfully requested that the informaiion which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10CFR2.790. Correspondence with respect to the prop'ietary ,
aspects of the Application for Withholding should reference CAW 92 269 or the supporting Westinghouse affid3vit. CAW 92 269 and be addressed to R. P. I DiPiazza. Manager of Nuclear Safety Licensing Westinghouse Electric Corporation, P.O. Box 355, Pittsburgh, Pennsylvania 15230 0355.
4 Sincerely,
_nl-_ z. g William J. Cahill, Jr.
- CEJ/gj
( Pnclosures c - Mr. h. B. Fields, NRR w/ encl Mr. R. D. Martin, Region IV.w/o encl Resident Inspectors. (CPSES) (2) w/o encl a
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m-M 'og # TxX 92009 4
2 File # 903.6 630119dclo)
Raf. # 10C FR2.790
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NRCB 88 08 7t/ELECTR/C wmiam J. Cahm. Jr.
March 23. I992 crowne ren.J<u U. S. Nuclear Regulatory Commistion Attn: Document Contrul Desk Washingtcn. D. C. 20555
- UNIT 1
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC 5TATION (CPSES) 00CKET NO. 50 445 (RHR)
SUPPLEMENT AL EV ALUATION OF RESIOUAL HEAT REMOVA'.
LINES THERMAL STRATIFICATION AND LEAK-BEFORE BREAK (LBB)
OUALIFICATION REF: 1) TV Electric letter logged TXX-89246. f rom William J. Cahill. Jr. to NRC dated May 9. 1989
- 2) TV Electric letter logged TXX 89566. f rom William J. Cahill. Jr. to NRC dated August 9. 1969
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Gentlemen:
On May 9,1989. TV Electric submitted by Reference (1) an evaluation of potential thermot stratification effects andTVleak-before break qualification Electric subsequently submitted for the C'.manche Peak Unit 1 RHR piping, to address NRC concerns, which
- a supplem:'.al evaluation by Reference (2),
demonstr76-0 that RHP piping integrity will be mair,tained during plant operation and that the leak-before break criteria are satisfied.
Reference (2) also provided an overview of the RHR monitoring program and administrative controls that ensure issuer, arising from the monitoring Reference (3) provides a responst program are addressed in a timely manner.
to concerns pertaining to the timeliness of reporting RHR thermal cycling; sensitivity of monitoring equipment; and the type of welding performed at LBB evaluated critical crack locations discussed during a telephone conference on September 6. 1989.
YO[ ODS dg , 400 N.otive sweet Ls. st o.11u.Tenas 7520: