ML20138F925

Forwards Request for Addl Info Re Util 850502 Request to Use Alternate Pipe Break Criteria to Eliminate Arbitrary Intermediate Pipe Breaks in High Energy Piping Sys

ML20138F925
Person / Time
Site:	Comanche Peak
Issue date:	12/10/1985
From:	Noonan V Office of Nuclear Reactor Regulation
To:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 8512160200
Download: ML20138F925 (6)

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DEC 10 885 Docket Nos.: 50-445 and 50-446 Mr. W. G. Counsil Executive Vice President Texas Utilities Generating Company 400 North Olive Street, L.B. 81 Dallas, Texas 75201

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION - ELIMINATION OF ARBITRARY INTERMEDIATE PIPE BREAKS By letter dated May 2, 1985, from J. Beck to V. Noonan, TUGC0 submitted a request to use an alternate pipe break criteria that would eliminate arbitrary intermediate pipe breaks in high energy piping systems. In light of the NRC staff review of the CPRT Design Adequacy Program activities related to piping and pipe supports, the staff finds that additional information is required to complete our evaluation of your request. Enclosed is our request for additional information.

Should you need further clarification regarding this RAI, .please contact the Project Manager, A. Vietti-Cook on telephone number (301) 492-8083.

Sincerely, Vincent S. N w :an, Director PWR Project D.; rectorate #5 Division of PW2 Licensing-A

Enclosure:

Request for additional information cc: See next page Distribution Docket File M. Rushbrook NRC PDR ACRS(10) 851216o200 851210 L PDR L. Shao PDR ADOCK 05000445 A PDR NSIC S. Burwell PRC System D. Terao PD*5 Reading File i Division Director A

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O E. Jordan B. Grimes p

J. Partlow 1 Project Manager , t 0FC :PD#5 :PD#5 :PD#5  : 5 :PD#5 N. .

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Docket Nos.: 50-445 DEC 10 N and 50-446 Mr. W. G. Counsil Executive Vice President Texas Utilities Generating Company 400 North Olive Street, L.B. 81 Dallas, Texas 75201

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION - ELIMINATION OF ARBITRARY INTERMEDIATE PIPE BREAKS .

By letter dated May 2,1985, from J. Beck to V. Noonan, TUGC0 submitted a request to use an alternate pipe break criteria that would eliminate arbitrary intemediate pipe breaks in high energy piping systems. In light of the NRC staff review of the CPRT Design Adequacy Program activities related to piping and pipe supports, the staff finds that additional information is required to complete our evaluation of your request. Enclosed is our request for additional infomation.

Should you need further clarification regarding this RAI, please contact the Project Manager, A. Vietti-Cook on telephone number (301) 492-8083.

Enclosed is our request for additional information.

Sincerely, a4 o n PWR Proj ct Di ectorate #5 Divisio of PWR Licensing-A

Enclosure:

Request for additional information cc: See next page l

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'i W. G. Counsil Comanche Peak Steam Electric Station Texas Utilities Generating Company Units 1 and 2 cc: -

Nicholas S. Reynolds, Esq. Resident Inspector / Comanche P.?ak 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 Mr. Homer C. Schmidt Larry A. Sinkin .

Manager - Nuclear Services 3022 Porter Street, NW #304 .

Texas Utilities Generating Company Washington, D.C. 20008 Skyway Tower 400 North Olive Street, L.B. 81 Dallas, Texas 75201 -

Mr. Robert E. Ballard, Jr. Ms. Billie Pirner Garde Director of Projects Citizens Clinic Director Gibbs and Hill, Inc. Government Accountability Project 11 Pen Plaza 1901 Que Street, NW New York, New York 10001 Washington, D.C. 20009 David R. Pigott, Esq.

Mr. A. T. Parker Orrick, Herrington & Sutcliffe Westinghouse Electric Corporation 600 Montgomery Street P. D. Box 355 San Francisco, California 94111 i

Pittsburgh, Pennsylvania 15230 Anthony Z. Roisman, Esq.

Renea Hicks ~, Esq. Trial Lawyers for Public Justice Assistant Attorney General 2000 P. Street, NW

g. Environmental Protection Division Suite 611 P. O. Box 12548. Capitol Station Washington, D.C. 20036 Austin, Texas 78711 Nancy E. Wiegers Mrs. Juanita Ellis, President Spiegel & McDiarmed Citizens Association for Sound Energy 1350 New York Avenue, NW -

1426 South Polk Washington, D.C. 20005-4798 Dallas, Texas 75224

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Ms. Nancy H. Williams CYGNA 101 California Street San Francisco, California 94111 s

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Texas Utilities Electric Company Comanche Peak Electric Station Units 1 and 2 -._.

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Resident Inspector - Comanche Peak c/o U.S. Nuclear Regulatory Commission P. 0. Box 1029 Granbury, Texas 76048 Mr. John W. Beck Vice President Texas Utilities Electric Company Skyway Tower 400 N. Olive Street, LBd81 Dallas, Texas 75201 Mr. Jack Redding "

Licensing -

Texas Utilities Generating Company 4901 Faimont 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 Administrative Judge Peter B. Bloch V.S. Nuclear Regulatory Commission Washington' DC 20555 Berbert Grossman Alternate Chairman ASLB Panel U.S. Nuclear Regulatory Commission Washington, DC 20555 Dr. Kenneth A. McCollon, Dean Division of Engineering Architecture and Technology -

Oklahoma State University Stillwater, Oklahoma 74074 Dr. Walter B. Jordan -

881 W. Outer Drive Oak Ridge, Tennessee 37830 l - _. . . _- - - - - - . - - - . . . - . - . . . . . . -

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. . . .- ENCLOSURE . . _.

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210. Mechanical Engineering Branch In your letter from J. W. Beck to V. S. Noonan dated May 2,1985, you submitted a request to use an alternate pipe break criteria that would eliminate the need to postulate arbitrary intennediate pipe breaks in high energy systems. The staff review finds that additional infonnation is required to coniplete our evaluation. The staff requests that your May 2, 1985 submittal be supplemented to address the following items.

1. Provide a discussion of the extent and usage of welded attachments in high energy piping systems. Include in your discussion a description of the type and the proximity of any welded attachments where arbitrary

intennediate pipe breaks are to be eliminated. .

2. Address the design considerations used at welded attachments in ASME Class 2 and 3 piping systems. Specifically address for the main steam and feedwater piping, the measures taken to minimize the potential for fatigue failures at welded attachments which could be caused by excessive localized bending stresses, hannful thennal gradients, or large cyclic

stresses in the pipe wall.

3. Provide a discussion of the specific measures taken to preclude excessive steady-state vibration in those high energy systems where the elimination of arbitrary intermediate breaks will be implemented. Identify and provide a justification for those high energy lines where the elimination of arbitrary intermediate breaks will be implemented which are not included in the preoperational steady state vibration test program.

4. Address the design considerations used in those systems where large

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dynamic transients can potentially occur. Specifically, provide a detailed discussion addressing the specific treatment of the dynamic transient effects in the feedwater piping system (both inside and outside containment) associated with a feedwater isolation check valve closure following a postulated feedwater line break outside containment. The staff concern is related to the fact that need for pipe whip restraints to satisfy the AIB criteria is independent of the need for restraints for

] events associated with transients resulting from a postulated pipe l break. Elimination of arbitrary intermediate breaks does not eliminate '

the need for those pipe whip restraints intended to mitigate the cynamic consequences of a transient resulting from a postulated break.

5. Provide a more detailed discussion of the system design and operating procedures that have been implemented to minimize the potential for water hamer in the feedwater and auxiliary feedwater systems. Specifically address 1) the need to maintain steam generator water level above the auxiliary feedwater discharge pipe inside the steam generator, 2) tne need for operating procedures at low load or hot standy-by conditions to supply feedwater in the AFW bypass line continuously, and 3) the need for any instrumentation on the piping upstream of the steam generator auxiliary feedwater nozzle to monitor temperature for detecting the onset of steam backleakage.

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6.- Provide the preoperational test report demonstrating-the adequacy of7he--- '

l feedwater configuration to reduce or eliminate water-hammer as stated in l Section 10.4.7 of the CPSES SER dated July 1981.  ;

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7. In view of the piping stress reanalyses currently being performed by Stone & Webster Engineering Corporation (SWEC) for ASME Code Class 2 and 3 piping systems, provide a discussion of the treatment of ~these revised piping stresses with respect to the previous stresses calculated by Gibbs l

& Hill used for postulating pipe breaks. Specifically address the i responsibilities of SWEC and Gibbs & Hill relative to a) piping stress analyses used for pipe break postulation, b) high (and moderate) energy line break analyses, c) pipe whip restraints design, and d) procedures used to control the SWEC/Gibbs & Hill interface relative to high (and moderate) energy line break analyses.

8. In Attachment B-1 to your May 2,1985 letter, you stated that in the environmental analyses the governing cases for each room were analyzed to determine the worst environmental parameters for equipment qualification.

Provide more details addressing how the environmental parameters for EQ were determined to conclude that they are the governing case for each room. Confirm that all equipment in the spaces traversed by the fluid system lines for which arbitrary intennediate breaks are being eliminated is qualified for the environmental (non-dynamic) conditions that would result from a non-mechanistic break with the greatest consequences on i surrounding equipment.

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