ML20141G441
| ML20141G441 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/07/1986 |
| From: | Landers D TELEDYNE ENGINEERING SERVICES |
| To: | Noonan V NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM) |
| Shared Package | |
| ML20141G446 | List: |
| References | |
| 6410-37, NUDOCS 8601100249 | |
| Download: ML20141G441 (2) | |
Text
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WTELEDYNE q
ENGINEERING SERVCES 130 SECONO AVENUE WALTHAM, M ASSACHUSETTS 02254 (617) 890-3350 TWX (710) 324-7508 January 7, 1986 6410-37 Mr. Vince Noonan, Project Director Comanche Peak Project U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Licensing Mail Stop P-234 Washington, D. C.
20555
Subject:
TUGC0 Use of ASME Code Cases N-397 and N-411 at Comanche Peak Steam Electric Station
Reference:
TUGC0 letter TKX-4610 from W. G. Counsil to V. Noonan dated November 18, 1985
Dear Mr. Noonan:
Inthereferenceddocument,TexasUtilitiesGeneratingCompany(TUGCO)has responded to NRC staff requests related to the use of the subject Code Cases at CPSES.
TES, at the request of the NRC staff, has reviewed the TUGC0 submittal and has the following comments:
1.
The implementation program defined in items (a) through (f) of Refer-ence 1 is acceptable to TES.
2.
With respect to item (f), TES agrees that WRC Bulletin 300 provides recommendations rather than absolute requirements. The intent of the
" Technical Position on Industry Practice" was to address areas in the Design Process which have been a concern in the past and to motivate the user to develop (or to use existing) in-house procedures for better control of the piping design process, including interfaces with other disciplines. TES would expect TUGC0 and/or SWEC to have procedures in place which address the piping design process, including interface control, whether or not the subject Code Cases are being used.
3.
The reasons and basis set forth for revision to the earlier design commitments are appropriate and acceptable to TES. The implementation of Code Case N-411 on an industry wide basis is supported by the technical community.
4.
With respect to the TUGC0 position related to determining the impact of the use of the subject Code Cases on current issues (i.e., external source issues) at CPSES, TES has some concerns which are primarily related to determination of root cause.
Generic implications of ex-ternal source issues, as related to piping and pipe supports, have o[
essentially been addressed by the TUGC0 decision to reanalyze essen-tially all large bore piping and supports and to sample small bore piping and supports.
t 9601100249 860107 P
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A ENGINEERS AND METALLURGISTS Aw.so L.
WTELEDYNE ENGINEERING SERVICES Mr. Noonan (USNRC) 6410-37 January 7, 1986 Page Two However, in determining the root cause and generic implications (beyond the piping and pipe support discipline) of external source issues, the Applicant should use the design commitments in place at the time the concern was raised. In order to do this the Applicant must be able to determine the effect of individual revisions to the design comitments or to evaluate external source issues using the original analysis.
The major reason for assuring that root cause and generic implication determination is done properly is to assure that other disciplines and/or components are not effected by the concerns in the piping and pipe support area.
5.
In summary, TES supports the use of the subject Code Cases for seismic analysis of piping at CPSES.
The concerns related to root cause and generic implications must be addressed by the Applicant.
Very truly yours, TELEDYNE ENGINEERING SERVICES M%As Donald F. Landers Executive Vice President DFL/lh cc:
L. Shao (USNRC)
C. Trammell (USNRC)
S. N. Hou (USNRC)
D. Terao (USNRC)
C. Poslusny (USRNC)
R. D. Hookway (TES)
J. Q. Cragin (TES) 6410 File (TES)
.