ML20129C281

Responds to 841221 Request for Approval to Use Later ASME Code Edition & Addenda than Specified Per 10CFR50.55a.Use of Listed Portions of Section III Subsection Nf of ASME Code Approved Subj to Implementation of Conditions Listed

ML20129C281
Person / Time
Site:	Comanche Peak
Issue date:	07/03/1985
From:	Noonan V NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To:	Spence M TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 8507160095
Download: ML20129C281 (6)

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UNITED STATES

[ g NUCLEAR REGULATORY COMMISSION 5 :j WASHINGTON, D. C. 20555

\...../ JUL 0 31985 i

Docket Nos.: 50-445- '

and 50-446 Mr. M. D. Spence President Texas Utilities Generating Company 400 N. Olive Street Lock Box 81 Dallas, Texas 75201

Subject:

Use of ASME Code Edition and Addenda for the Comanche Peak Steam Electric Station (Units 1 and 2)

The NRC staff has received your request for approval to use a later ASME Code Edition and Addenda than that currently in the Code and Standard Rule (10 CFR 50.55a), identified in a TUGC0 letter dated December 21, 1984.

Before addressing your specific request, the staff has asked that we clarify to TUGC0 the applicability of ASME Code Editions and Addenda, as well as the scope of the 10 CFR 50.55a rule, in order to resolve any misunderstandings on the part of your staff.

The most recent version of 10 CFR 50.55a, dated March 30, 1984, approves the editions of Section III of the ASME Boiler and Pressure Vessel Code, through the 1980 Edition and Addenda through the Summer 1982, and is only applicable to Code Class 1, 2 and 3 components. The rule does not addressSection III components such as: Class MC (Subsection NE); Supports (Sub-section NF); and Core Support Structures (Subsection NG). The NRC staff is currently in the process of approving additions to Section III of the Code through the 1983 Edition and Addenda through the Summer 1984, that are also Jon1 applicable to Code Class 1, 2 and 3 ccmponents. As currently written, this new revision of the rule does not address such components as those constructed to Subsections NE, NF and W of Section III, as noted above. Caution should be exercised by your staff in the use of Code Editions and Addenda for which approval is pending. Use of any such Code Editions and Addenda is at~TUGC0's own risk.

A O hh0[8l45 PDR

Mr. M. D. Spence JUL 0 31985 While NRC staff approval is not required by 10 CFR 50.55a to utilize a later Code Edition and Addenda of Subsection NF (Section III) of the Code, staff approval of the standard used for the construction of the component supports is required by General Design Criterion 1 of 10 CFR 50. Implementation of a later Code Edition and Addenda must be in conformance with NCA-1140 of both the later Code Edition and Addenda of Section III, and the Code of record for the facility. It is the responsibility of TUGC0 to ensure that all related provisions of the Code are adhered to, particularly when selected paragraphs and tables of a later Code Edition and Addenda are used in conjunction with the Code of record. To that end TUGC0 shall prepare a listing for NRC staff review of those Code provisions TUGC0 considers related and with which it will .

comply. The list shall be compiled from the later editions and addenda speci-

- fied in the December 21, 1984 letter corresponding to the eight selected para-graphs or tables requested to be used. NCA-1140(f) requires plant owners to '

determine the acceptability of both the Code Edition and Addenda established b in the design specification, and in later revisions of the design specifi-cation with regulatory authorities such as the NRC.

Since your request for approval to use the later ASME Code Edition and Addenda was received when the design of Comanche Peak Units 1 and 2 is largely com-pleted, provide the reasons and basis for requesting the revision to earlier design commitments. Since there is extensive testimony by your representatives and the staff on the use of Section III of the ASME Code for Comanche Peak, the staff requests that you perform a careful review of the hearing record to identify whether (and in what manner) each of the request items may affect the before the ASLB. In addition, the staff requests that you earlier identifytestimony whether (and in what manner) the request items may relate to:

(a) The Motions for Sumary Disposition submitted by TUGC0 concerning piping and pipe supports; (b) Matters which were reviewed by Cygna in the Independent Assessment Program; (c) The comments of the NRC's Technical Review Team; (d) The comments of the NRC's Special Review Team; (e) The comments of the NRC's Construction Appraisal Team.

With respect to your December 21, 1984 request, the NRC staff finds the use of the listed portions of ASME Code Section III Subsection NF acceptable when the following have been implemented:

(a) Identify in the FSAR affected component supports (i.e., by systems and supports) to which the later Code requirements are to be applied;

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Mr. M. D. Spence ,s n JUL 03 1985 g Q j .- <cy-(N i Ti3

( TUGC0 shall assure that all-code related requirements have been met; a listing of the related requirements shall be submitted for NRC staff review as discussed above.

(c) Applicable design specifications and required design

-documents shall be revised.

Further, we request that you consider whether a Construction Permit amendment is necessary. If not, please provide your rationale.

Should there be further questions concerning this subject, please contact the Project Manager.

Sincerely, (NLIGINAL Slud BY 3 Vincent S. Noonan, Director for Comanche Peak Project Division of Licensing cc: See next page DISTRIBUTION: .

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. JUL 0 3 ESS Mr. M. D. Spence Comanche Peak Steam Electric Station Texas Utilities Generating Company' Units 1 and 2 cc: .

Nicholas S. Reynolds, Esq. Resident Inspector / Comanche Peak Bishop, Liberman, Cook, Nuclear Power Station Purcell & Reynolds c/o U.S. Nuclear Regulatory Commission 1200 Seventeenth Street, NW P. O. Box 38 Washington, D.C. 20036 Glen Rose, Texas 76043 Robert A. Wooldridge, Esq. Regional Administrator, Region IV Worsham, Forsythe, Sampels & U.S. Nuclear Regulatory Commission Wooldridge 611 Ryan Plaza Drive, Suite 1000 2001 Bryan Tower, Suite 2500 Arlington, Texas 76011 Dallas, Texas 75201 Larry A. Sinkin .

3022 Porter Street, NW #304 g_ Washington, D.C. 20008 Mr. Robert E. Ballard, Jr. W. G. Counsil Director of Projects Executive Vice President Gibbs and Hill, Inc. Texas Utilities Generating Company 11 Pen Plaza Skyway Tower New York, New York 10001 400 North Olive Street, LB#81 Dallas, Texas 75201 Mr. A. T. Parker Ms. Billie Pirner Garde Westinghouse Electric Corporation Citizens Clinic Director P. O. Box 355 Government Accountability Project Pittsburgh, Pennsylvania 15230 1901 Que Street, NW Washington, D.C. 20009 Renea Hicks, Esq.

Assistant Attorney General David R. Pigott, Esq.

Environmental Protection Division Orrick, Herrington & Sutcliffe P. O. Box 12548, Capitol Station 600 Montgomery Street Austin, Texas 78711 San Francisco, California 94111 Mrs. Juanita Ellis, President Anthony Z. Roisman, Esq.

Citizens Association for Sound Energy- Trial Lawyers for Public Justice 1426 South Polk 2000 P. Street, NW Dallas, Texas 75224 Suite 611 Washington, D.C. 20036 Ms. Nancy H. Williams CYGNA 101 California Street San Francisco, California 94111

JUL 0 31985 Texas Utilities Electric Company Comanche Peak Electric Station Units 1 and 2 cc:  ;

Resident Inspector - Comanche Peak c/o U.S. Nuclear Regulatory Commission ,

P. O. Box 1029 Granbury, Texas 76048 Mr. John W. Beck Manager - Licensing Texas Utilities Electric Company Skyway Tower 400 N. Olive Street, LB#81 Dallas, Texas 75201 Mr. Jack Redding -

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Licensing t_ Texas Utilities Generating Company 4901 Fairmont Avenue Bethesda, Maryland 20814 William A. Burchette, Esq.

Heron, Burchette, Ruckert & Rothwell Suite 700 1025 Thomas Jefferson Street, NW Washington,-D.C. 20007 Mr. James McGaughy Southern Engineering Company of Georgia 1800 Peachtree, Street, NW Atlanta, Georgia 30367-8301

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