ML20209G009

Provides Addl Comments on Comanche Peak Response Team Program Plan.S&W Procedures,Guidelines & Design Criteria Should Be Reviewed in Detail by NRC & Teledyne Consultants Before S&W Piping Reanalysis Effort Initiated

ML20209G009
Person / Time
Site:	Comanche Peak
Issue date:	07/22/1985
From:	Terao D NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To:	Shao L NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
Shared Package
ML20209F938	List: ML20209F931 ML20209F978 ML20209G009 ML20210S689 ML20210S767 ML20210S785 ML20210S804
References
FOIA-86-657 NUDOCS 8508080574
Download: ML20209G009 (2)

Text

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f;0TE T0: Lawrence Shao, Engineering Group Leader Comanche Peak Project, Division of Licensing FROM: David Terao, Mechnical Engineering. TRT Comanche Peak Project, Division of Licensing

SUBJECT:

ADDITIONAL C0fdENTS ON CPRT PROGRAF t PLAN In addition to my comments provided to you in my note dated July 15, 1985, I have the following additional comments based on a more detailed review of the CPRT Program Plan:

1.) The acceptability of the CPRT Program Plan to adequately address all pertinent External Issues in the piping and pipe support area can only be determined in the implementing procedures, guidelines, and design criteria.

The Program Plan as written does not provide that level of detail. Therefore, the specific Stone & Webster Engineer Corporation's (SWEC's) procedures, guidelines, and design criteria which implement the broad piping and pipe support program described in the CPRT Program Plan needs to be reviewed in detail by the staff and Teledyne consultants before the SWEC piping reanalysis effort is initiated.

2.) The Program Plan does not adequately address the details of SWEC's effort in the reanalyses of small bore piping (2 inch nominal pipe diameter and less). The staff and Teledyne will need to review the details of the sampling basis to be used by SWEC to verify the adequacy of small bore piping and support design when they are available.

3.) It appears that in some cases if the design of piping and pipe supports does not meet licensing commitments, then an evaluation will be performed to determine whether the deviation is safety significant or not. If the deviation is not safety significant, then the licensing connitment could be changed.

For piping and pipe supports this evaluation should not be permitted with respect to ASME Code compliance. Deviations from the Code should be treated as a deficiency. However, certain licensing commitments should be allowed to change based on a review by the staff on a case-by-case basis (e.g. the use of Ccde Case N-411 in lieu of damping values established in licensing commitments).

4.)lt should be clarified whether the SWEC reanalysis effort on t.oth piping and pipe supports will be considered the design of record. If so, then the SWEC

,, procedures should clearly indicate how the new design of record will interface with related and dependent activities being performed by other design organizations (e.g. elimination of arbitrary intermediate pipe breaks).

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l Lawrence Shao -

5.) Without having reviewed the implementing procedures, it appears that the overall SWEC effort focuses too heavily on the piping stress reanalysis for a

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' reduction in piping system loads and stresses. The pipe support reanalysis effort appears to focus on the reduction in pipe support loads for acceptability. However, many of the External Issues related to pipe supports

, 3' exist irrespective of the magnitude of seismic loads. Thus, the staff (and Teledyne) must assure itself that the SWEC procedures thoroughly address the 7 evaluation of the External Issues for each affected pipe support independent of whether the pipe support seismic loads increase or decrease. Furthermore, the staff should determine whether the SWEC procedures contain an adeouate provision to acceptably implement the Progran Plan's commitment to perform a

' detailed walkdown by pipe stress and pipe support engineers to identify pctential problems other than those identified in the External Issues.

> 6.) Theanalysis.

piping CPRT Program Plan does not address the Westinghouse Class 1 auxiliary

' Although the Westinghouse scope of responsibility related to the usual NSSS scope (i.e. reactor coolant loop) should not be reviewed by CPRT, the applicant should provide a rationale for excluding a review of the llestinghouse Class 1 auxiliary piping analysis.

7.) The CPRT should provide a preliminary schedule for the effort described in

,..' their Program Plan by action items.

8.) It is obvious that the CPRT/SWEC effort will require many close interactions with the staff and Teledyne. The staff should clearly establish the proper format for such interactions with respect to protocol, noticing meetings, meeting transcripts, and documenting communications (especially for the benefit of Teledyne).

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,'. David Terao, Engineering Group Leader Comanche Peak Project Division of Licensing cc: R. Bosnak