ML20210A814

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Transcript of Comanche Peak 860828 Meeting in Bethesda,Md Re S&W Reanalysis of Piping & Pipe Support.Pp 1-64. Supporting Documentation Encl
ML20210A814
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Site: Comanche Peak  Luminant icon.png
Issue date: 02/08/1986
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OTG VA UN11ED STATES NUCLEAR REGULATORY COMMISSION IN THE MATTER OF: DOCKET NO:

COMANCHE PEAK REANALYSIS OF PIPING AND PIPE SUPPORT BY STONE AND WEBSTER LOCATION: BETHESDA, MARYLAND PAGES: 1- 64 DATE: THURSDAY, AUGUST 28, 1986 jgTIE ACE-FEDERAL REPORTERS, INC.

Official Reporters 444 North Capitol Street Washtneton, D.C. 20001 8609170350 860709 (2(i2) 347-3700 DH ADOCK 0500 S NATIONWTDE COVERAGE o

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1 CR27973.O BRT/sjg UNITED STATES OF AMERICA 2 NUCLEAR REGUALTORY COMMISSION 3

4 MEETING ON

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5 PIPING AND PIPE SUPPORT BY STONE AND WEBSTER 6

7 Nuclear Regulatory Commission Room 422 8 7920' Norfolk Avenue Bethesda, Maryland 9

10 Thursday, August 28, 1986 11 The meeting convened at 9:30 a.m., Mr. L. D. Nace of 12

  • Texas Utilities Generating Company presiding.

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J 27973.0 2 BRT 1 PROCEED'INGS 2 MR. NACE: First of all, I would like to 3 introduce the people we brought. I'm Larry Nace, vice 4 president, nuclear engiheering construction for TUGCO.

5 With me from TUGCO is Jack Redding in the back row, John 6 Finneran, and Bob Dacko. From Stone & Webster is Ed Siskin, j 7 Ron Klause, Alan Chan, Louis Nieh, Lief Dietrich, Elwin 8 Evans and from R.L. Cloud and Associates, in the back row, 1

9 Bob Cloud.

10 From my standpoint we see three separate 11 j purposes of today's meeting. First, we have come'to 12 initiate what we . intend to be rather complete, open and 13 frank discussions on the scope of TUGCO's pipe stress and 14 pipe support requalification effort as executed by Stone &  !

I 15 Webster. l 16 We expect to convey to the Staff a complete  :

17 understanding of the scope, the methods, the procedures, 18 the practices and policies of this piping requalification 19 effort.

20 Secondly, we intend to convey fully the status 21 of the PSAR, with respect to this program, and outline some  ; l 22 changes we intend to apply for. We will propose several  ;

23 clarifications and additions to the PSAR, which we believe f 24 will update the FSAR to reflect the requalification by 25 alternative analytical methods employed by Stone & Webster.

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1 In some cases the proposed changes merely brinq  !

-2 the piping sections of the SAR into compliance with the 3 intent of NUREG-0800, to which this' project has not been l

4 committed. l i

5 Thirdly we intend at this meeting to fulfill a  !

6 promise we made earlier this year to fully inform the Staff 7 with respect to complete description of the ASME code j 8 editions, addenda and code cases, which are used in the i 9 requalification program.

10 While unit 1 of the plant is under ASME 11, ANI 11 control, all design work -- if you go into ASME 11 to do 12 some design work, it refers you to the applicable sections i l

i 13 of ASME III. We'll discuss which versions of ASME III we i

'14 are using. And we trust that, upon completion of this j 15 briefing, this meeting and your subsequent reviews of our  ;

16 application, that you'll find this requalification effort 17 to result in the most complete, thorough and 18 state-of-the-art piping system design and verification 19 effort undertaken by any NTOL applicant to date.

20 I'll turn the meeting over now to Ed Siskin, and ,

l 21 let him start introducing the Stone & Webster effort. .

I 22 MR. NOONAN: Before you actually start that i 23 process, maybe a couple of things so I understand. Today 24 you will give us every change you are proposing in total? f I

25 MR. NACE: Every change we know of and intend to I

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2 MR. SISKIN: That we intend to make is the l

3- functional word. There are some things that may very well .

4 come about at some later date.

5 For example, we are going to list all the 6 computer programs that we are using. Some we are required ,

7 'to list, some we probably aren't required to list but we 3 8 are going to include it for completeness anyway. We have 9 some potential problems where we may need additional 10 computer programs to properly analyze them. So we may 11 decide we want to use another program at some time in the 12 future.

13 In fact there are two potentials right now that .

1 14 we are thinking about. We haven't decided to use them yet. i 1

15 So I don't want to give the impression that this is it, we i t

16 are never going to come back to the well. This is it as {

17 far as we know today.

18 MR. NOONAN: Okay. The computer program that i

19 you are talking about, are these programs that the Staff  ;

20 has already seen and approves? Am I going to have to go i 21 through a computer program review?

22 MR. NACE: We'll show you -- one of our slides l

23 will show you where you have seen it before. That's the 24 intent of the whole presentation. We are going to show you 25 that this is something not very astonishing.

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1 MR. NOONAN: One other question. You made a  !

2 statement that some of these changes are to meet the intent ,

3 of NUREG-0800. When you say that, clarify that for me a  ;

4 little bit when you come across those particular points.

5 MR. NACE: They will be brought out in the i

6 i appropriate' slides, too.

7 MR. SISKIN: .To answer that question, basically  ;

8 we are meeting all the design requirements of NUREG-0800.  ;

9 That's the scope of our job right now and that's the ,

10 guidelines that we have been using since day 1. That does 11 not make a commitment for any other part of the project.  !

12 MR. NOONAN: Just for the record, this review l 13 offort will be undertaken by the engineering branch people; 14 Mr. Bagchi is sitting here and Dave Terao, plus consultants, l

[

15 Don Landers and his people. So those will be the main >

16 people that we'll have uorking on the Staff support. l 17 MR. ~T'RAMMELL: Before we get into this any j i

18 deeper, I would like to do some more mundane preliminaries.

19 I would liko, for example, to introduce the NRC Staff and I 20 go around the room so overyone here knows our people. I'm 21 Charlie Trammell, one of the assigned project managers. l 22 This is Annette Vietti-Cook, also assigned to Comanche Peak. ,

23 Could we just go down the table here, everyone say their 24 name and aff111ation. Vince, we know who you are.

25 MR. TERAO: Dave Torao, NRR, engineering branch.

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27973.0 6 i 'BRT 1 MR. BAGCHI: Goutam Bagchi, engineering branch, I 2 mechanical engineering section.

3 MR. CHEN: Paul Chen.  !

4 MR. PALMER: Adam Palmer on behalf of CASE, 5- l MR. DACKO: Bob Dacko, licensing.

j 6 MR. CHAN: Alan Chan, Stone & Webster. -

] 7 MR. KLAUSE: Ron Klause, Stone & Webster, j i

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8 MR. SISKIN: Ed Siskin, Stone & Webster. ,

J l

9 j MR. PLOCKI: Peter Plocki, Heron, Burchette, 10  ! Ruckert and Rockwell, here on behalf of Tex-La Electric I i i

! 11 l Co-op. ,

12 k MR. CARLINGTON: Dave Garlington, GDS Associates. t i

13 MR. TRAMMELL: We are going to pass around a l

I

14 j clipboard and ask overyone to put their name and ,

I i 15  ! affiliation on it, so we'll make a copy of that and bind it i

j 4 l 16 into the record.

i . ,

j 17 l- MR. FINNERAN: John Finneran, TUGCO.

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{ 18 '

MR. HIEH: Louis Nieh, Stone & Webster.  ;

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! 19 MR. DIETRICH: Lief Dietrich, Stone & Webster. '

i 20 MR. EVANS: Elwyn Evans, Stone & Webster.

I 21 MR. ASHER: Hans Asher, NRR.

22 MR. ZHONG: Wanli Zhong, IAEA fellow from China, j 23 now working on Comanche Peak.

f 24 MR. REDDING: Jack Redding, TUGCO.

i 25 MR. CLOUD Bob Cloud, Cloud Associates.

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1 MR. CHANDLER: Larry Chandler, office of the 2 general counsel.

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3 MR. NOONAN: Maybe we ought to explain for the 4 record what this is about, where Mr. Zhong is.

5 MR. TRAMMELL: Mr. Zhong is on an IAEA 6 fellowship from the Peoples Republic of China. He's here 7 for six months to learn the licensing process for U.S.

8 I reactors. China presently has two Framatone units under 9 consideration, I guess, at this point, near Hong Kong, and 10 t as I understand it, the containment l one reactor which is, 11 ' is maybe up 40 feet above the ground somewhere else in ,

12 l China.

13 MR. ZHONG: Near Shanghai.

14 MR. TPAMMELL: So he's here with others from  :

15 i China, here for the licensing function and there's someone j 16 else with him, also for six months, in the quality 17 fassurancearea. l l I 18  ! MR. CHANDLER: But nobody is interested in the

!i 19 lhearingprocess. ,

I I

20 i MR. TRAMMELL: As I say, I'm passing around a 4

l clipboard; if you would please sign in your name so you can 21  ;

22 l read it and your affiliation, I'11 make copies of that for ,

23 whoever wants them and we'll put a copy in the record.  !

24 , That's all I have in the way of preliminaries. Thank you.

25 (Discussion off the record.)  ;

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1 MR. ASHER: I would like to find about the scope , f 2 of pipe support anchors to the concrete. Are you going to 3 ldealwiththat? l I

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4 MR. NACE: Not really.

5 MR. SISKIN: No. The reason I paused before I  :

6 answered that is, what is covered is going to be two parts:

7 one, our presentation, and two, the response to what the f 8 i NRC raised.  !

9 t1R. ASHER: No, the question was you, yourself, .

l 10 l are you going to cover the interface between the concrete  ; ,

11 and pipe supports? [

t 12 ,

MR. SISKIN: We are not going to bring that out. '

i 13 l We are not requesting an FSAR change in that area.  ;

14 I want to keep something in perspective before i j i

15 we start talking. ,

t 16 Remember when Stone & Webster was brought on {

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17 board in this ef fort a year ago, the plant was basically }

18 l complete. Our charter from tir. Counsil, our firm direction, l f

19 was that we were to requalify it using the best available j l

20 technology.

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21 First class job, defendable in a forum today, is  ; l i  ;

22 not necessarily a forum when the plant design parameters } }

23 were established more than 10 years ago. 1 l

24 The other point he made at that time was to be l t

25 fully open in what we did to the NRC, to a third party  ;

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l reviewer, to any intervenors or anyone else.

1  ;

2 Jn summary, on that point, what ue've got is the 3 original design concept from the 1974 era, and the 4 reanalysis being done to 1986 standards. The cbjective is 5  ; to have a first-class job, a first-class product, better 6 than would have been expected five to 10 years ago.

7 In order to document exactly what we are doing, 8 l some changes in the FSAR are going to be required. Some to 9 just reflect what is being done; some as much for 10 information as anything else.

11 If you look at each individual item, I'm sure ,

1 12 there will be a discussion: Is a particular item more or 13 less conservative than what was originally perceived?

14 j I think it's very important to address the i 15 package as a package. Overall, you are going to end up 16 with a product which is substantially more conservative and 17 substantially higher in quality than would have been the 18 case some time ago.

I 19 Rather than going off into individual items at 20 this point, let me have Ron, now, go through, stop by step, 21 each of the changes we are talking about making. Then we f 22 can be prepared to go into more detail on anything you f

23 would like. Ron? l 24 MR. KLAUSE: I'll try to center these as we go

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l 25 along. It looks like my words are wider than the projector.

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l 27973.0 t 10 BRT 1 There are two parts of my presentation today, l

2 The first part is to cover the PSAR updates for piping 3 requalification program. The second part is to cover the 4 code editions and addenda that are being used in this t

5 requalification effort.

6 In our program action plan, whicn is a road map 7 to indicate the type of requalification that we are going 8 ,

to be doing, we said in there that we may seek those 9 fchangeswhereappropriatetothePSAR.

10 (Slide.)

k 11 3 MR. TRAf tt! ELL: I would like to indicate that we 12 i! have been joined by Don Landers and Bob Hookway of Toledyne.

' i 13 [ MR. KLAUSE: As part of my program we have i.

14 , reviewed the FSAR to identify the changes required to i

15 { reflect what we are doing. ,

1 16 4 (Slide.)

f 17 l In review of the FSAR, we had three objectives 18 t in mind. These were to assure that the FSAR accurately 19 reflects the SWEC design methodology; to include the

!I 20 computer codon that SWEC 10 using in the requalification 21 i effort; and to update the FSAR to meet the intent of the 1

22 !standardreviewplan, NUREG-0000, f or piping and supports.

I 23 j (Slide.)

24 This summarizes the topics that we are going to i

25 ' be covering this morning, and shows whether they aro ,

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1 reflections of the SWEC methodology or changes to meet the i 2 current NRC regulatory position, or changes to provide  :

3 clarification.

4 This chart is intended just as a summary. I'm  ;

5 going to cover each topic in detail.

6 (Slide.)

7 The first topic is the computer programs 8 utilized by Stone & Webster. The proposed change is to 9 specify, in the FSAR, those computer codes that Stone &

10 Webster is using in the requalification effort. Currently,  !

~i 11 the FSAR does not show these codos, so it needs to be i

12 corrected to list them. l l

13 Now, as Larry said earlier, this plant was not i

14 committed to the standard review plan, but we are using the 15 standard review plan as guidance for piping and supports in l 16 the requalification effort.

17 (Slide.)

I  !'

18 These computer programs that we intend to uso 19 are listed here. Wo have tried to portray where those t i

20 codos have been used beforo.

21 The Xs represent inclusion of the codes in other 22 dockets, '.he PSAR of other dockets, and the dots represent  !

23 codes that are used on those projects. These dots are 24 representative of computer codes that are data processing f I

25 in nature or arithmetic, or public domain programs. l l

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BRT I 1 MR. NOONAN: Do they use this on Diablo at all?  ! <

t 2 MR. KLAUSE: They are the SWEC dockets. We I l t

< 3 don' t believe there is a requirement to list all the codos l 4 in the dockets. But some utilities have chosen to do so. '

5 MR. TRAMMELL: The X means it was used? '

i l 6 MR. KLAUSE: X means it was listed in the docket I I

7 of the FSAR. -The dot means it'was used but not required to j

, t 8 be listed in the docket. These dots are' programs that are l 9 data processing in nature, arithmetic, or public domain i 10 programs.

l i, 3

11 MR. SISKIN: In each case, each of these .

12 programs is qualified per Stone & Webster's engineering l

13 assurance program.

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] 14 MR. KLAUSE: That's correct. r 15 (Slide.) l

} 16 The second topic is the SSE loading combination.

l 17 The proposed chango is to delete SSE from the loading j 18 combinations in emergency plant conditions, or service 19 lovel C.

4 l

j 20 The reasons for these changes are for l I

l 21 consistoney with the standard review plan, class 1 analysis, ,

i ,

22 and Stone & Webster methodology.

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23 The present version of the FSAR considered the l j i f 24 plant omorgoney condition -- considered SSE in the plant I  !

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25 omorgency condition. This was based on Reg Guido 1.48, but l [

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1 this has been superseded by the NUREG-0800. We intend to i 2  ! apply this to ASME class 2 and 3 piping systems, and class 1

3 1 1. .

1 4 MR. TERAO: Does the proposed change also 5 include adding the SSE to service level D? Or are you l

6 i saying you are deleting SSE from service level C, period.  ;

7 MR. KLAUSE: Deleting it from service level C and 8 including it in service level D.

b 9 i f1R. TERAO: It's not clear from the frame there.

10 MR. NOONAN: What does that do for you? <

i 11 MR. KLAUSE: What does that do for us? j 12 , (Slide.)

i 13 It provides a couple of things. Like I said, it 14 provides consistency, what's excepted today by Staff 15 thinking -- l 16 MR. NOONAN: As far as hardware is concerned. l l

17 ,

MR. KLAUSE: It's certainly a relief as far as 18 o the -- using the faulted event for emergency _ conditions. I 19 guess, as a by-product, it can be elimination of supports.

20 (Slide.) -

21 The third topic is the seismic response in the 22 zero period acceleration region. The proposed change is to 23 add the method in NUREG/CR-ll61, December ' 79, to address i 24 high frequency. seismic responses in the ZPA region in the 25 amplified response spectrum.

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1 MR. BAGCHI: I'm sorry, I was not following.

2 , Could you go back to the previous slide?

3 MR. KLAUSE: Sure.

l . t r

4 (Slide.)

i I 5 MR. BAGCHI: In the application you indicated i

6 class 2 and 3 piping systems and class 1, 2, and 3 piping 7 supports. j  ;

i 8 MR. KLAUSE: That's correct. l t

9 MR. BAGCHI: So this does not apply to class 1 ,

l' 10 piping itself?  ;

l 11 MR. NACE: Stone & Webster's scope does not 12 include class 1 piping. l t

13 MR. BAGCHI: But this FSAR change, who's scope j t

14 is it? i l . 6 i 15 MR. k' '1S C
There's a section in the FSAR that l  !

i 16 deals specifice'ly with class 1 piping and already l  ; ,

17 specifies this loading in the faulting.  !

l .

4 i 18 MR. BAGCHIt So it's going to be in 3.9B as i 19 opposed to 3.9A?

20 MR. KLAUSE
That's right. l I
21 MR. BAGCHI Thank you, i

I j 22 MR. KLAUSE: The reason for this change is the l i

l 23 existing FSAR is silent on the issue. We need to include l t 24 this change to explain how it's being addressed in our  ;

I 25 requalification program. ,

T i

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2 We need to ensure that participation of all 3 significant modes used in response spectra analysis are 4 accounted for in piping systems. i i

5 MR. NOONAN: Is that because the cutoff on the 6 f requency now is too low and you can take .it that high? Is  !

7 that what you are doing? l 8 l MR. KLAUSE: That's correct.

9 MR. NOONAN: How far are you taking it?

10 MR. KLAUSE: In our design criteria CPPP-7, we 11 specify 50. 50 plus the ZPA. l l

12 MR. NOONAN: Okay.

13 MR. BAGCHI: Maybe we need to go back to that 14 one more time. How much of the physical mass, or do you 15 ever check whether the entire physical inertia of the 16 system has been included?

17 MR. CHAN: We do not check the physical mass.

18 The reactor has taken the correction with the ZPA analysis 19 so you would include everything in our analysis. We did 20 not make any cutoff or any approximation; we basically have 21 included the whole spectrum.

I 22 MR. BAGCHI But there's nothing in the program

]

23 to see what amount of the total inertia is participating?

24 MR. CHAN: I don't believe there is.  !

l Okay.

25 MR. KLAUSE:

I l

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1 j (Slide.)

2 'I-The next topic is combination of peak dynamic

.)

3 responses. {

4 l The proposed change is that the peak dynamic '

5 responses of piping systems due to seismic, LOCA or 6 occasional loads are combined by the SRSS technique.

7 The reasons for the change, again, is that of l 8 consistency with Stone & Webster methodology and class 1 .

i 1

As an additional reason for the change, 9 q analytical methods. , J 10 we believe this would minimize the plant maintenance, thereby 11 As a by-product, this would -- f Ireducingpersonnelexposures. .

I 12 this change would result in the elimination of some 13 snubbers and supports, which we believe is current with the 4

14 latest Staff thinking. ,

15 MR. BAGCHI: Is there an independent support 16 motion analysis? This is just module analysis combination --

17  ! MR. KLAUSE: Right. l 18 MR. NOONAN: You take the squaren of all of them

19 and put them all underneath the square root sign?

l k

20 MR. CHAN: Right. I i .

21 MR. NOONAN: You don't bring out the primary --  ;

22 MR. CHAN: This is the combination of different  ;

23 loading events. The peak values from seismic combined with 1 24 location of event and RIP LOCA.

25 MR. LANDERS: Clarification. If one of the {!

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1 loading events are in history, why are you going to'--  !

t 2 l MR. TRAMMELL: Would you all speak up a little 3 bit? Especially when the air compressor is going on.

, ,4 4 MR. LANDERS: The question was: Are.you going i 5 to have SRSS times history peaks with spectra peaks?  !

i 6 MR. CHAN: Yes.

7 MR. KLAUSE: The next topic is plastic analysis, i i

8 (Slide.) i I

9, l

The proposed change is to revise. 3. 9B.1. 4.1 to I

I 10 include the option permitted by the code to use plastic ,

11 analysis for class 2 and 3 components. l 12 MR. CHANDLER: Does that involve a change of l

13 code as well? The code presently listed in paragraph 3.9B? f 14 MR. KLAUSE: Yes. j i

15 MR. BAGCHI: It's the ASME code he 's talking i

, 16 about. I 17 MR. SISKIN: Let's defer that question until 18 later on when we explain what. codes we are talking about l- '

19 using and that will be consistent with this.  !

l

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20 MR. CHANDLER: Fine.  !

l The reason for the change l's to I 21 MR. KLAUSE:

22 provide a basis for the qualification of class 2 and 3 23 piping-for local effects. It's appropriate to use the 24 class 1 approach in NB-3228 to evaluate these localized' 25 effects.

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1 It is our intent to inform the Staff 2 specifically where this type of analysis is going to be i

3 utilized, and seek their approval as required. i

'4 MR. MIZUNO: To date, how many specific examples 5 do you expect to notify Staff that you are going to be 6 using or have already used? ,

7 MR. KLAUSE: We haven't asked specifically for 8 the use of this method yet. We believe in the local 1

9 bearing type stresses for piping it may be sought.

10 ,

MR. MIZUNO: Also, on your basis for change, you I I 11 ) make the statement that it is appropriate to use this t

12 approach, the class 1 approach for class 2 and 3. To be

i 13 more expansive?  ;

14 MR. SISKIN: There is no procedure.specified for l 15 class 2 and class 3 approach. It just says.it should be 16 addressed. Since we are addressing it, we' thought it would 17 be appropriate to use the one specific technique that is 18 permitted. I 19 MR. KLAUSE: If it's good for class 1, it's good i I

20 for class 2 and 3 also.  ;

21 (Slide.)  !

22 The next topic is functional capability. The j 23 proposed change is to add functional capability assurance ,

24 requirements for piping systems by the criterion in  ;

i 25 NEDO-21985. Although there is a previous licensing l l

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-f 1 commitment to provide functional capability for stainless i 2 steel elbows in response to your FSAR number 3, this change 3 expands the commitment to all essential systems to meet the 4 requirements.of the standard review plan. The reason is to i I

5 assure operability of essential piping systems during and 6 after a postulated event -- accident condition. j 7 (Slide.)

8 f The next topic, spectral broadening,. code case

'9 N-397, and damping values, CC-N-411. '

10 The proposed change is to apply these 11 alternative rules to spectral broadening and damping values [!

12 in the ASME code.

I 13 The reason for the change is to update these 34 already-approved alternative rules and the conditional  !

t I

15 requirements for their use.

16 The basis is letters from Mr..Noonan to 17 Mr. Counsil as shown here.

18 This area is a highly researched approach for i

19 analysis utilized in more than 20 plants. l 20 MR. BAGCHI: Do you plan to use N-397 21 extensively?

22 MR. KLAUSE: No. To date there has been no plan 23 to use 397, but we put it in there --

i 24 MR. BAGCHI: For completeness?

25 MR. KLAUSE: Just for completeness.

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1 MR. BAGCHI: Will you notify the Staff when you 2 do so? ,

3 MR. KLAUSE: That's a requirement. We have to  ;

4 notify you and list it-in the'FSAR.

5 (Slide.) ,

6 The next topic is stress cycles for the seismic 7 event. The proposed change is to specify a maximum of 50 8 maximum amplitude loading cycles for the five OBE events 9 and 10 maximum amplitude loading cycles for the SSE. event. ,

10 This reason for change is consistency with Stone 11 .

& Webster methodology used on other dockets-which are  ;

I 12 l licensed, and to conform to the current regulatory ,

I 13 acceptance criteria.

14 Now, specification of stress cycles are ,

15 generally not required'for class 2 or 3 systems. Currently, 16 there are questions concerning fatigue for certain supports  !

17 and for welded attachments in the vicinity of arbitrary l 18 intermediate breaks. We would use this change to further 19 justify the fatigue as not a problem for these supports.  ;

20 MR. SISKIN: Or determine if there is a proolem.

21 MR. KLAUSE: Or determine if there is a problem. {

i

. 22 (Slide.) i 23 The next topic is to discuss other FSAR updates.

24 These proposed changes listed here are procedural in nature, l

25 to meet the intent of the reg guide, of NUREG-0800 of the j l

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1 standard review plan.

2 Just looking at a couple of these, the 'first one, 3 the valve modeling technique is to include the eccentric 4 mass effects; the second is to add the containment 5 displacement loading combination, which was previously not 6 considered for this plant. One of the others, the fluid 7 transient analysis method is to identify the techniques 8 lthatweareusing in the requalification program. The 9 current FSAR is vague in this area, as far as transient 10 analysis is concerned.  !

11 The reason for the change, again, is for l

12 consistency. By upgrading these sections of the FSAR, it 13 will reflect the Stone & Webster design criteria being used .

I 14 in our piping requalification program. This will be  !

l 15 included for the ASME class 2 and 3 piping systems and for j

i 16 the class 1, 2 and 3 supports.

17 (Slide.)

18 MR. LANDERS: Every time you talk about these 19 kind of changes and you talk about class 1 supports, if the 20 class 1 piping systems do not have these changes, are you

21 going to redo the analysis of the class 1 systems to 22 include these effects? j i

23 MR. KLAUSE: I want to make sure I understand I 24 your question, Don. our scope is to qualify --

-l 25 MR. NOONAN: I understand. But you are saying i

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.BRT 1 the application includes class 1 supports. You are not 2 doing class 1 piping analysis. If the class 1 piping 3 analysis does not include these effects, then I don't think 4 you can apply these changes to the supports, since the 5 loads are going to come from the piping analysis.

6 MR. KLAUSE: The loading combinations that we 7 have specified in our design criteria has been transmitted-  ;

8 to Westinghouse. They are using --

9 MR. LANDERS: So Westinghouse is going to redo r

10 lthepipinganalysisandtheyare including these ef fects 11 also?

12 MR. KLAUSE: That's correct. l 13 MR. LANDERS: So these are applicable to class 1 14 also? They are going to hear from someone else on what the  ;

l 15 class 1 effects are? ,

i 16 MR. SISKIN: I think in most cases the class 1  !

17 l already includes them. The one Mr. Bagchi talked about 18 already was specified in class 1. i 19 MR. LANDERS: You were quite clear in the 20 transparency there was. In this you are not. I'm 21 wondering if we are going to have a disconnect here.  ;

22 MR. NACE: The answer is no, we weren't planning i i

f 23 to have, because what was asked for was the Stone & Webster I

24 scope. But we certainly don't plan to have a disconnection. l l'

25 MR. NOONAN: Can we have an answer to that? I ACE-FEDERAL REPORTERS, INC.

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I 1 don't want to h' ave this hanging. I guess what Don is 2 asking is what are you going to -- are these changes 3 included in the class 1 piping analysis? And, if not, are i 4 they going to go back and redo it?

5 MR. NACE: I think it's all in there. We'll get 6 back to you.

7 MR. KLAUSE: Westinghouse had their own methods ,

8 for doing fluid transient analysis. That's described in

~

9 the FSAR in their program.

10 MR. NOONAN: Okay.

11 MR. KLAUSE: We, like I said, have transmitted l

12 our design criteria for piping to Westinghouse for 13 consistency. They are using loading combinations, as we i

14 have described, for the requalification of class 2 and 3 ,

15 piping systems. So we know that, for instance, the ,

16 containment displacement and the thermal and seismic anchor [

17 ! displacement, they are included in their analysis of the l l i 18 ASME class 1.

19 MR. LANDERS: I think somebody needs to be j

  • i 20 responsible for making sure that that happens.  ;

21 MR. NACE: We will do that.

22 MR. KLAUSE: Okay.

23 (Slide.)_

24 The last topic is the ASME code edition 25 paragraphs and code cases -- I'm sorry. I got my slides I

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l 1 }outoforderhere. It's the ASME code of record, is the 2 .last topic.

3 The proposed change is to state that the ASME 4 Section III, '74 edition, including the summer '74 addenda 4

5 subsections NC, ND, and the winter '74 addenda subsection NF, 6 is the ASME code edition of record. I 7 The reason for this change is to clarify in the l 8 FSAR what the code of record is, which currently the FSAR 9 is not specific. It just states it's ASME III. So this is 10 lforcompleteness.  !

I 11 l MR. LANDERS: Does this mean that 1974 edition  ;

12 with no addenda is what I would look at'for NCA, for i

13 , example, and for the appendices? Because you are quite l

l. .

14 l specific in pointing out summer addenda as applicable to NC, j i

15 landND, and I'm assuming that's "only." So what do I look i l

16 i . at for NC and the appendices, just the '74 edition?  !

! l 17 MR. KLAUSE: And then I'll cover later sections l l

18 1 in the next slide.

19 MR. SISKIN: The exceptions will be shown on the i 20 next slide. )

i 21 MR. LANDERS: Thank you. l 22 MR. KLAUSE: Which brings us to part two of my i I

23 presentation.

I, 24 .(Slide.) l 25 As I stated earlier, TUGCO made a commitment to I

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I i 1 the Staff to provide a list of the code cases and later l 2 sections of code that are being used in the requalification 3 effort. As permitted by paragraph NA-1140 of the '74 l 4 edition of the code, specific paragraphs in more recent 5 editions and addenda of the ASME code have been invoked.  ;

6 These are shown in attachment 1, which I'll put next.

7 But these later sections are adopted primarily 8 because the '74 code either did not provide guidance or was t

9 not complete. So these later. sections clarify the intent 10 of the '74 code'and provide additional guidance. .

11 (Slide.) j 12 Attachment 1 is these later sections of the code.  !

13 I think they are all included in your handout. i 14 (Slide.)

15 Attachment.2 are the code cases being utilized.

16 You'll notice on this list -- it needs a little i i

17 explanation. If you look under the column " listed in Reg l

1 i

18 Guide 1.84 or 1.85," you'll see all of those code 19 l indications with the exception of one have been included in i

20 Reg Guide 1.84 or 1.85. The one that has not, specific {

There's a dash, l 21 permission to use this is in process.

i 22 blank over on the side of this because we don't know what i i

I 23 the requirements will be as far as listing this is in the 24 FSAR.

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i 27973.0 26 BRT I would look at N-397 and N-411. We show "yes" out in the i i

2 column of utilization required to be listed in FSAR. This t

3 is not a requirement of 1.84 or 1.85, but it is a 4- requirement for TUGCO to use these code cases, and the ,

l 5 conditions that were tied to them. So these will be listed ,

6 in the FSAR.

7 Now, TUGCO has met its commitment by providing  !

8 this list. Information for these code cases and the later 9 sections of code are included in our design criteria, 10~ !CPPP-7, which has been transmitted to the' Staff and I think  !

11 it would be appropriate if you would review this list and l l  :

12 get back to us if you have any questions on any of those j i

13 later sections for the code cases. l l

14 This concludes my presentation. i 15 MR. CHANDLER: If you could help out a poor dumb j l

16 lawyer for a moment, when I had asked my question earlier I l

17 on, I believe it was sltde 5, on plastic analysis, and I  :

I 18 asked whether there was a change in code involvement, Ed 19 suggested I wait. Now you have gone through the listing of I i

20 codes.  ;

i 21 I gather what you have said on slide 10, ASME l 22 code of record, is that you are now specifying certain c'de o ,

i 23 editions and addenda that you will be utilizing. I l

1 24 understood you to say that right now is simply a reference i i

25 to Section III, ASME Section III, without specifying a  ;

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27973.0 27 BRT 1 particular edition or addenda or anything else.

2 MR. SISKIN: Exactly. ,

3 MR. CHANDLER: But do I understand that the i 4 reference to these particular editions and addenda of the 5 codes represent changes from the editions and addenda used  ;

6 previously for Comanche Peak or is.that an incorrect 7 understanding? ,

8 MR. KLAUSE: I think we are confusing computer 9 codes with later sections of the ASME code here.

10 MR. CHANDLER: . Help me out.

11 MR. KLAUSE: The later sections of the codes, 12 some of these were included in the previous analysis. Some i i

13 are additions. l t

14 MR. CHANDLER: All right. l 15 MR. SISKIN: Basically what was done was the 16 FSAR just satisfied ASME III. They used the editions that [

t 17 we are talking about here, but in general did not use all  !

l  !

18 of the specific editions that we have mentioned here, so we  !

19 are formalizing exactly what was done for our reanalysis.  ;

I 20 It in most cases is consistent but not in all cases is  ;

21 consistent with what was done before we arrived on the  !

22 scene. i l

23 MR. CHANDLER: Where there are differences, is l 24 that identified? In other words, where a particular code  !

25 was not previously specified --

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1 l MR. SISKIN: The basic code was previously used.

2 Not necessarily specified.

3 We did not go back and do a detailed review to i l

4 find out what Gibbs & Hill or anybody else did before we i 5 came on the scene. Our intent was to have our effort stand 6 alone.  ;

7 MR. CHANDLER: Then let me ask you, Larry: Is 8 the project undertaking to do that?- For example, I 9 understand TERA has some effort to do some reconciliation.

10 MR. NACE: I do not Delieve it is included in  :

11 TERA's scope. The method -- the reason we'are bringing i i

12 ; these later addenda up is because Stone & Webster has used j l

13 that alternate method for analyses and it is important to  ;

. . i 14 ! list what is inherent within their codes and standard j i

15 i practices. Their alternate method is just another way of j 1

16 verifying the design.  !

17 ! MR. CHANDLER: All right.

l i

18 l MR. NOONAN: All right -- go ahead.

l 19 j MR. LANDERS: On attachment 1 you have a list of  ;

!' l 20 all of these different editions and paragraphs that you are j i

21 ) using. I'm assuming, knowing how you people do things, i

22 that in adopting these paragraphs you have gone through the 23 process of reviewing the code with respect to 24 interdependence of other sections and that somewhere there 25 is -- that effort could be looked at. True?

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1 MR. KLAUSE: Correct.

2 MR. SISKIN: We are not playing a game of

~3 assuming the most desirable part of one and the most 4 desirable part of the other.

5 MR. NACE: I do want to raise a point here, 6 answering Don's question, which is back to Mr. Chandler's 7 question.

8 TERA, as the third party, is o'erviewing v this 9 whole exercise. If there is a disconnect, it would become 10- apparent, 11 MR. CHANDLER: How are you using-the term 12 " disconnect" there, so I understand that?

13 MR. NACE: I think your concern I heard to be 14 the same as Don's.

15 MR. LANDERS: My concern is a common disconnect ,.

16 concern and I think --  !

I 17 MR. SISKIN: What Don is concerned about is ,

18 there is.a revision that has a different set of rules. You 19 take one.small piece of this new set of rule, a couple -- f i

20 one small piece of the other set of rule --

21 MR. LANDERS: As shown in attachment 1 that's i

22 what you have done, but to get to that point, you have done 1

23 a lot of work to demonstrate that it stands alone. l 24 MR. SISKIN: That's right. That's no problem. 1 I

25 As Ron made the point, the majority of these  !

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t i

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1 l -later references are just to pick up where earlier. editions 2 did not explain how to do something or what the acceptance 3 criteria was, or something like-that -- provide some i

4 credibility to our own requirements.

t 5 MR. TRAMMELL: While we are on the subject of 6 codes, I know this is probably not a problem but I just 7 thought I'd ask you. Section 50.55(a) of our regulations, l 8 codes and standards sets out the editions of the code that  ;

9 will be used for nuclear power plants for ISI, IST, for 10 design, based on, probably -- I think based on'the i

11 submission of a construction permit.

f 12 We don't have any conflict, here, with the  ;

i 13 regulations, do we?  !

l 14 MR. SISKIN: No.

15 MR. NACE: No, we don't. l

. i 16 MR. CHEN: I have a question. This is Paul Chen.

l (

17 lonattachment

, 1, last item, a concern which was raised,  !

l '

18  ; concerning bolt holes, arose because of the limitations on l

19 the sizes of holes. This summer 1985 addendum allows you l

20 to use larger bolt holes. Are you going to be ignoring the j i

21 technical concern that was raised by CASE or not?

~

l 22 MR. KLAUSE: We don't ignore any technical 23 concerns by CASE. '

24 MR. CHEN: The summer '85 addendum says you can ,

25 use larger bolt holes. CASE's concerns don't go away. Are I

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l 1 you still going to be addressing the concerns that were l l

2 raised relative to the smaller bolt holes?

l \

3 MR. KLAUSE: I don' t believe there is a 3 i

4 requirement to go further than that, since the holes are  !

i 5 accepted by this addendum. i 6 MR. MI2UNO: Are you speaking from a piping '

i 7 support and qualification standpoint? Are you approaching 8 it from being able to prevail at a hearing? -

i

.9  ; MR. KLAUSE: Hopefully, both.

i 10 MR. TERAO: I would like to clarify what the f 11 Staff conc'ern is. The issue of bolt holes has a long  !

12 history, as I'm sure you are aware of.

i' J 13 Recently, in discussions about what will be

]

I

[ 14 covered by the CPRT program plan, a discussion came up 15 whether or not -- let's say past QA/QC practices were  :

16 deficient. In the case of the bolt holes, there is a j 17 l stipulation in the guidelines previously that the use of I  !

18 bolt holes for a.1-inch bolt happened to be a 16th of an I -

l 19 inch greater than what the code specified. So the question l 20 was: Why was that acceptable at the time?

! 21 l From your understanding of current code l l  :

22 practices, that has been clarified. From a technical 23 standpoint, you are saying from a technical and engineering 24 standpoint, the code has accepted the use of the 16-inch 25 oversize. bolt hole for concrete expansion bolts. But the ,

l I

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I 27973.0 32 i BRT 1 question which still hasn't been answered is whether or 2 not -- why was it accepted in the past? Why was this bolt  :

3 hole acceptable in the past? 1 1

4 MR. NACE: First of all, I think the questions  ;

I 5 you are asking are questions that need to be asked, if they 6 need to be asked, to the CPRT, TRT-type of people. i 7 Stone & Webster's purpose is to completely ,

i 8 requalify class 2 and 3 piping systems and class 1, 2 and 3 .,

9 supports. So that at the end of their effort we are all 10 convinced that we have a design that is safe to operate and l i

11 lthatwecanalldefendfromatechnicalstandpoint. f L

12 MR. NOONAN: Let me suggest something. I think l 13 at the end of this session what we'll do is we'll caucus i 14 with the Staff and the kind of question, maybe, that you -

15 are asking is the kind that I need to look at and see 16 whether I do send those forms to the CPRT, and we have -

l 17 something outstanding -- I'll send those to the appropriate 18 members of the CPRT, and hopefully we'll get a response 19 back. .

I i

20 l MR. TERAO: I just needed a clarification right j 21 now of exactly what Stone & Webster's scope was and l 22 Mr. Nace has clarified that for us. This is probably the j 23 dilemma that TERA is under. Because at this point they --

24 I believe they have been asking Stone & Webster these same l

25 type of questions, the kind of questions which will require  ;

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1 a technical organization to resolve the -- these type of l 2' questions. '

I 3 Now, TERA, themselves, as I understand it, is  !

4 not performing these ~ type of analyses. I'm just trying to 5 clarify today exactly if Stone & Webster was going to do ,

6 this analysis or not.  :

7 MR. SISKIN: Stone & Webster may very well get i 8 involved in other technical issues. In order to keep the 9 line of demarcation completely clear, I would propose not 10 to do it on the pipe stress and support project. I would  !

11 use other people. I want to keep the scope of this project i ,

12 as originally defined.

  • 13 If there's other technical work we need to do, I 14 will have other people off this project involved in it.

l 1

15 MR. NOONAN:

Okay.

16 I have one other question, Ron, on attachment 2. l 17 There was a note that said: Request for specific NRC j (

i

?

18 approval is in process. What does that mean? I 19 MR. SISKIN: It means the letter is -- ,

l 20 MR. TRAMMELL: The check is in the mail. [

l 21 MR. NACE: The letter was signed Tuesday. The

{-

t 22 check is in the mail.- l l \

23 (Laughter.)

i <

24 We carefully arranged it so you didn't get it {

25 before the meeting. j i ,

i .

l 2 1 I;

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i 2

f MR. TRAMMELL: I was wondering if this might be' 3 a good time for a short break?

. l .

l 4 MR. TERAO: I would like to bring up one more  !

5 l point, a technical point. On the use of code case 318-2, i i >

6 this has been accepted in the Reg Guide 1.84, Revision 24,

  • 7 as you so note.

8 l When you say the " utilization required to be i

l 9 [ shown in the PSAR," I would like a little more A

10 lclarificationofwhat l

that means.

i 11  ! MR. NACE: I'm sorry, Dave, I was writing and 12 j not listening. ,,

l

+

13 MR.~TERAO: The last._page, attachment 2 of your  : ,

i 14 alide, in the middle you show N-318-2 code case, listed in  ;

! t 15 l the reg guide, you say yes, and in the second column, you l>

t i 16 have " utilization required to be shown in the FSAR." I

]'

17 just needed clarification on what you mean by'that.

18 MR.'NACE
Well, take, for example, the 397, 411. i i

19 l The specific letter we got back from Vince asked that we j i

20 '

show in the FSAR where they are used.

21- MR. EVANS: Reg Guide 1.84 itself' requires I ,

I

, 22 listing in the FSAR, so we are just complying with the reg i 23 guide itself.  !

I i

! 24 l MR. TERAO: So it's not only listing the use of l

25 the code cases but the reg guide itself states: identify f

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35 BRT 1 the FS AR, the method of attachment, piping system involved 2 l and location of the system where the case is to be applied.

3 MR. EVANS: That will all be there.

4 MR. HOOKWAY: The only code case not listed by

  • 5  ; the accepted reg 1 guides is 253-4. I think -2 was accepted

, t l

6 j by the reg guide. '

t 7 Can you tell me -- describe briefly the 8 difference between the 4 and the one that has been accepted? l 9 MR. EVANS: As far as we know, nothing has been 10  ! accepted. ,

1 ,

11 MR. HOOKWAY: Nothing? No 253? '

! i 12 l MR. TERAO: I would like to clarify that. l ,

i 13 I In Revision 24 of the Reg Guide 1.84, I believe 14 you are correct, and 253 -- that had not been accepted at 4

15 that point. But, subsequently, the NRC Staff has been f I i 16 reviewing the code cases and is proposing what code cases i i .

j 17  ! should be added to the next revision of the reg guide. So, ', ,

18 the 253, Revision 2, has, to date, been accepted by the i e

4 19 I Staff. i f

i 20 MR. EVANS: Very well. Let me say something to l l i

21 make you happier. That is, for our' purposes, Rev. 2 and l'  ;

t 22 i Rev. 4 are identical. So if you are going to accept Rev. 2, i

. i i

23 we can use Rev. 2 just as easily as we can use Rev. 4.  ;

I I c 24 MR. TERAO: That was the gist of our question. l ,

t l

i 25 If you can tell us what the difference between Rev. 2 and i

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2 MR. EVANS: No difference. ,

3 MR. CHAN: We requested the latest one. That's ,

S 4 ,

why we put Rev. 4 in.

5 MR. TRAMMELL: Would this be an appropriate time j 6 for a short break? ,

l 7 j MR. NACE: DJ you want just a break or do you l i

, t l

8 intend to cadcus?

9 j MR. TRAMMELL: We could use a few minutes to 10 ll discuss a few of the things. I don't need a caucus but I l ,

n 11 'l do need a break.  ! .

l ,

12 / (Laughter.) j l '

13 ( MR. NACE: I need a break, too. At this point, i*

14 what our intent was was to have whatever discussion of this  !

15 point you all feel necessary. Our intent is to go back and

^

16 formalize the changes we are requesting and to get our j I 17 j request to you by about the 12th of September, no later

, 18 3 chan that, documenting what we discussed here today. t 19 MR, NOONANt Are you done with your presentation ,  ;

l l Time?

20 ,

at this point? Then maybe I will -- let's go ahead

{

21 ( and break. I will caucus with Staf f for a few minutes.

I l

l

, 22  ; (Recess.) l 1 I I 23 i MR. TRAMMELL: We are back. We have got copies I l

4  ! ,

24 l of the attendance list here for everybody that would like. [ ,

25  :

There's numerous copies there.  !

i l l l

. 6 t

I i i l

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4 1 MR. NOONAN: During the caucus we probably 4 2 generated a couple of thousand questions for yo~u but -- , ,

i

3. some of the questions you might hear today will be 4 questions that are outside the scope of Stone & Webster.  ;

l 5 When you hear that, you know, just tell us that you think 4

6 it's outside your scope. What I'll probably do is document l 7 those types of questions in a formal letter and send it to  !

8 the CPRT, and request answers. If you hear those kind of ,

t 9 l questions--identifyit.

! 10 MR. NACE: Okay. j 11 l MR. NOONAN: One of the main concerns, now, the  !

i 12 Staff has, is when Stone & Webster came on site, they came {

13 on site and looked at a system that was built and sitting f

14 there. Now, today, you have done a reanalysis and you are 15 making a number of modifications to that system. l 16 i What the Staff is concerned about is making sure 17 we understand what all those changes are, making sure we 18  !

jcan identify all those changes that took place to date and 19 )insomecaseswhywasit necessary to make those changes..

20 Why did you feel it was necessary to make those changes.

21 That's kind of briefly. You'll get additional questions )

\

22 from the Staff.

I 23 MR. SISKIN: It is our intent to provide that as 24 part of the report. We will be giving really two reports f 25 as follow-on to the previous information: -one is ACE-FEDERAL REPORTERS, INC. .

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l, ,

i 1 identifying what we are doing and why, and the secono is .

2 fwhatwefoundandwhat changes we have made and why they ,

1 3 are there, as well. ,

. 4 MR. NACE: In addition to that, through the .

. 5 50.55(e), we have been trying to keep ycu informed on the -

6 , progress and status, puttin(J numbers of changes in there by  ;

i

! 7 grouping, which you will probably want to look into at some 8 point in tino.

9 MR. NOJNAN: Okay.

10 f4R. SISKIN: You will b6 deluged with that i

11 j information.

12  ! MR. TRAMMELLs Are we talking about a results ,

l 13 ' report? DSAP 97 i f .

14 MR. NACE: Jack, you have to answer that. ,

i 15 Technically it comes from TEkA. I 1 16 I MR, EEDDING: Jack Redding , from CRT. It's I l l 17 really SRT, senior review tean. l 18 fik. CH.\NDLER: When will the Stone & Webster 19 l reports be issued? DO you have some time frame for thofe? ,

'I 20 MR. SISKIN: We . ire no; prepared to give it yet, {

21 at this point. l 22 MR, NACE: Stone 4 W0bster'E task is a 23 corrective action portion of the CPRI proCram rClated to i I

24 o piping and pipe supports. That is .s portion of input. to  ; [

i 25 TERA, in the formulation if the final CPRT products, '.f you ; <

i l .

i '

i

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1 l will. But their portion, then, leaves us with a  ;

2 , requalified -- Stone & Weoster's portion leaves us with a  !

i 3 requalified ' design.

~

4 MR. CHANDLER: I understand. I think last week 3

5 l there was a meeting that we held with the applicants in l

6 l Region 4, in Texas. And at that time I had asked a 7 question based on the progress report that was submitted by i 8 l the applicants, in response to the board, which listed l

9 a several dates for input on piping and pipe support-related 10 issues. One of those-dates called for submittal of  ! ,

! 11 information, of a results report, by the end of October 12 9

lOf '86.  ;

l >

, 13 MR. REDDING: That's a tentative date and we are e

lshootingforthat.

14  ;

i  ! i 15 l MR. CHANDLER: I understand. And that report i i t 16 fwillbetheCPRTresultsreportonDSAP9. ,

17 MR. REDDING: That's correct.  !

18 MR. CHANDLER: In -- I believe it was mid '87,  ! i k  !

19 there is a report due, I understood, on at least the i 1 20 initial output of Stone & Webster on their efforts. Is 1 4 ,

21 Wrong?

lthatcorrect?  ;

i 22 MR. NACE: Your report is to TERA --

l 23 #

MR. CHANDLER: That's part of the problem I see.  !

24 MR. NACE: The sequence is, he has to issue a ,

f 25 report to give TERA sufficient time to review so TERA can  ;

j i  :

, I J

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1 meet that "end of October" commitment. I'm not sure what 2 the '87 report is you are talking about. Jack, do you 3 remember? ,

4 MR. REDDING: That's the joint advocacy, the 5 total report that we are shooting for. There will be some 6 input from Stone & Webster on that, also.

7 MR. SISKIN: In each case, our report is a i 8 precursor-to the report you are talking about.

9 MR. CHANDLER: I understand. So it will be 10 somewhat sooner'than the end of October of '86. Fine.

11 MR. NOONAN: I think Larry is indicating that 12 the progress report that we got is somewhat confusing as to l 13 the number of dates in there, as to when the Stone & I 14 l Webster work -- when we would get a report. Some dates i 15 probably meant that maybe it was the total corrective l 16 action work that's going to be done sometime. .It wasn't 17  ; really clear. That's why we had some question as to when  ;

I  !

18 I we could expect, at least the report out of you that the i 19 Staff will look at -- what I refer to as the Stone & l 20 Webster report.

I 21 MR. SISKIN: The reason I'm saying put an "s" on  !

22 the end of it, there will be reports.

23 MR. NACE: And you are also speaking {

l 24 specifically of the unit 1 portion? .

i

i 25 MR. NOONAN
You know, this effort includes both  :

4

! i i l l

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1 units 1 and 2. I 2 MR. NACE
.Yes. I 3 MR. NOONAN: So we best make sure we are doing j i

4 both units here. Not just unit 1.

5 MR. SISKIN: But the October report and what we 6 are preparing to support that Oct'ober report is strictly f

, 7 unit 1. i I 8 .MR. NOONAN: Unit 1. Okay.

9 MR. TERAO: Can I get a little clarification ,

4 10 while we are on this topic? The CPRT program plan is quite [

11 clear with respect to the type of results reports and I i 12 collective evaluation reports that TERA will be issuing. ' '

~

13 But it doesn't explain at all or describe any of the

~

14 reports that Stone & Webster will be issuing. '

15 Now that you are talking about issuing reports,  ;

i 16 plural, could you give us a preview of what these reports l

17 will be? We have seen this generic technical issue report.  !,

. I I

18 What other reports would stone & Webster be issuing? i

[ 19 MR. NACE: Just one, really. j

! t 20 HR. SISKIN: Really, the next one to support the  !

! 21 October thing -- it's all done. Here is the final result,

22 MR. NACE
That might be what Mr. Chandler is l

23 talking about. f i

24 MR. SISKIN: The report that we are preparing 25 now and sometime to support the end of October, basically I I l l i

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l reports the completion of all the piping analysis 2 preliminary results with respect to the' supports -- ,

3 walkdown in that report as well? I 4 MR. KLAUSE: Large bore for piping and final 4

5 walkdown report.

6 MR. SISKIN: Yes. It does not include small 7 bore?

. 8 MR. KLAUSE: No.

9 MR. TRAMMELL: If you would like to confer on 2 10 this subject, take a minute to do that.

s 11 MR. KLAUSE: We are trying to get our facts  ;

l i 12 straight here.  ;

13 MR. TRAMMELL: We'd be happy to take a short I

(

14 break so you can get it clear. I want to get clear in my  ;

15 mind what reports you all will be producing and when. l l

16 ,

MR. SISKIN: Obviously everything we are going  ;

i  !

17 I to do will eventually be documented. In what forum we  ;

I 18 present it to TUGCO and eventually to the NRC may very well l

19 change. But the information necessary to support the l 4

j 20 October 30th report is in preparation now. It should be ,

21 available sometime before October 30th.

22 MR. NACE: You are really asking the wrong group 4

23 that question about the CPRT reports. I haven't kept that f 24 close tabs on their report schedule.  ;

I 25 Jack? You probably know better than I -- l I

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BRT 1 l MR. NOONAN: Maybe I'll turn to Mr. Redding, and f t

2 ask Mr. Redding if he would try to clarify Dave's. question- {

3 for us. l 4 MR. REDDING: Dave's question was relating to ,

!i 5 Stone & Webster. l 6 Actually, Stone & Webster -- we have not, so to 7 speak, committed to issue Stone & Webster reports. But 8 they will be part of the filed information that supports .

9 these results reports from the CPRT program. Stone &

10 Webster is actually right now in the process of making some  !

11 other proposals in some other areas that Mr. Counsil talked 12 about. But we are not at this time prepared to talk about ,

i 13 i when, exactly, Stone & Webster is going to be prepared to l 14 issue any reports that will subsequently support results i i

'15 reports from the SRT. j 16 l MR. NACE: Let's start again. Somebody ask the  ;

I 17 i question that you want clarified. j 18 MR. NOONAN: I think what Dave was indicating --

19 you correct me -- when you said there will be reports, i, 20 plural, I think Dave is trying to figure out what that is.

21 MR. TERAO: We want to know what type of reports 22 will Stone & Webster be issuing when they complete their 23 piping and supports redesign? As opposed to reports that 24 TERA will be issuing. I I

25 MR. SISKIN: We are going to issue a document, j ACE-FEDERAL REPORTERS, INC.

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BRT l 1 exactly what we have done, what we found, and what the i i 2 results are. Hopefully, the information in large bore pipe 3 _and supports is going to be out sometime before the end of I

4 October.  ; ,

5 MR. NOONAN: That would cover the large. bore ,

6 piping. Do we have similar reports for the other piping?

7 MR. SISKIN: Small bore and walkdowns.

8 MR. MI2UNO: These reports will be for both unit 9 1 and unit 2?

i 10 MR, SISKIN: Eventually. Yes, at this point we j

, i 11 are talking just about unit 1. i i 12 MR. NOONAN: But we will see reports for unit 2.  !

I 13 MR. LANDERS: Excuse me, I have to admit I'm l i-14 more confused than the honorable Mr. Chandler. He cover l F

! 15 large bore and small bore piping, and supports are covered j I 16 by -- how can TERA write these reports?

  • l 17 '

MR. NACE:. They can't.

, i 18 MR. LANDERS: We don't anticipate seeing DSAP 9 19 in '87.

20 MR. NACE: DSAP 9 covers all of it in its  !

21 entirety. I don't recall what was in the progress report 22 but the progress report was addressed to the unit I large  !

23 bore report.

24 MR. LANDERS: There's going to be a partial 25 results report, maybe?

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27973.0 45 BRT 1 MR. SISKIN: The DSAP 9 will be broken up. The !

2 report at the end of October is just for large bore.

i '

3 MR. MIZUNO: Let's just ~ say the progress report  !

l 4 had no -- no breakdown that way. That's fine. Thank you 5 ,

for telling us. j 6 MR. SIS KIN: I don't know what the progress 7 report said.

l 8 MR. NACE: We are all speculating here, i

9 MR. SISKIN: I just know the information we are 10- giving would support a progress report supporting large-  !

11 bore for unit 1.

12 MR. MIZUNO: That's good information. I just l 13 want to tell you that's new information we never saw in the i

14 progress report before. l l

15 MS. VIETTI-COOK: But the proposed amendment to l I

' 16 the FSAR is going to be here next month; is that what you l

17 said?

18 MR. NACE: Yes. I 19 MR. NOONAN: Let me talk about that one for a i 20 moment, the proposed amendment change here. The last I i i

l 21 heard, you are going to submit something on September 12th?

22 MR. NACE: By September 12th.

i 23 MR. NOONAN: When would you be looking for some j 24 type.of staff action?  !

25 MR. NACE: Well, obviously we'd like it I i ACE-FEDERAL REPORTERS, INC.

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1 processed as soon as possible. We just need to eliminate 2 uncertainties.

3 MR. NOONAN: I'm looking at the standpoint of I

4 eventually this is going to go into a hearing. In order to 5 prepare for that, whatever that day is, what do you think 6 you need? Are you talking you need something by the end of 7 -September? Or you need somet'hing by 1 November? I am just-8 trying to get an idea.

9 MR. NACE: I think these cases, the 1st of i

10 November will be adequate. We should try and do it by that l 11 time.

I 12 MR. NOONAN: You'd like to see something out of I l

13 the Staff in about two months, nevertheless, is what you 14 are telling me? l 15 MR. LANDERS: You are almost going to be roped ,

16 into doing something with respect to approving it just by l

~!

17 i l l approving DSAP 9. I 18 MR. TRAMMELL: Is this a critical path item? I 19 MR. LANDERS: This information is going to be in j 20 DSAP 9. f l

21 MR. SISKIN: That's the end of October.  !

22 MR. NACE: It's a critical path item from the 23 standpoint of finishing the Stone & Webster copy from the 24 standpoint of requalifying pipe and pipe supports on unit 1.

I 25 That can't be finished until you all are comfortable with j l,

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l 27973.0 47 BRT-l 1 the codes and use. i 2 MR. TRAMMELL: I have a question related to that. l 3 Never mind. l 4 MS. VIETTI-COOK: I want to make-sure on this. .

5 When.you submit this, I want to make sure, is it going to 6 be proposed amendment or -- {

7 MR. BAGCHI: No.  ;

8 MR. TRAMMELL: For amending the FSAR, this'is 9 definitely a proposal. And I want to make it clear from 10 people starting certain pages in the FSAR with questions on 11 what's approved and not approved. My preference on this f 12 would be to submit, in whatever form you want, in letter 13 form -- rather -- a proposed amendment to the FSAR as a i 14 package. We.will review that package and report out on it l 15 and assuming that it gets approved or partially approved or 16 whatever happens to it, we send you a letter back saying:  ;

I 17 ,

Okay, now send us FSAR pages.

t 18 I'd prefer to do it that way because, frankly, i 19 it can get confusing as to what, especially when you mix l i

20 apples and oranges. You may send us a FSAR amendment  ;

21 addressing only piping and pipe supports and then slip in i 22 in the last page.something about a radiation protection  ;

i 23 engineer or something like that which is unrelated, or i I

24 maybe prior approval has already been given. It mixes  !

25 things up.

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27973.0 48 BRT 1 I'd rather keep this as a proposed package.  !

l 2 lThenwhenwereportoutonthatpackage,yousubmita 3 conforming change to the FSAR.

4 MR. NACE: They have already gotten it mixed ,

5 because.we have two cases already approved that you direct 6 us to put in the FSAR.

7 MR. TRAMMELL: We already approved it? You  ;

8 haven't done it yet, then wait on it and it can all be done 9 at once if you haven't done it yet anyway.

9 10 MR. NACE: This is a- departure f rom the normal l 11 practice, isn't it?

12 MS. VIETTI-COOK: No. I don't think so. In

-l 13 some cases, special cases, you have proposed amendments to j r

14 the FSAR.

15 MR. BAGCHI: We have submitted amendments by ,

16 letter in the past, the assumption being if the Staff has a 17 problem with it, changes can be made before it becomes an j 18 official amendment. So that's the way we would handle this  !

19 one, j i

20 MS. VIETTI-COOK: In'certain cases you have done 21 it that way.

22 MR. TRAMMELL: 411 was done that way; 397. It's 1

23 not totally consistent, but we can be overwhelmed by this j I

24 process. A voluminous amendment all of a sudden gets i 25 inserted into peoples' pages in the different technical i

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27973.0 49 BRT 1 groups and all.of a sudden'we've got a paper problem.

2 MS. VIETTI-COOK: What happens, 40 amendments  !

3 come in here, it goes to all the various branches, they  ;

4 pull out pages, insert pages, and nobody knows whether we 5 have-ever approved it. Do you know what I mean? l 6 MR. NACE: Your document control program. j 7 MR. REDDING: We have separated this proposal l-8 from any other amendments we have been making, so this will 9 be a separate amendment package.

10 MR. NOONAN: We'll talk logistics of that. I ,

I 11 don't want to take anymore time on it.

i 12 I guess I would like to turn to the Staff and i 13 see what other kind of questions they have. I know there 14 were some additional questions. . Whoever wants to speak f

15 first?  ;

16 MR. LANDERS: In your submittal on plastic  ;

i 17 analysis, would you define the appropriateness for the i 18 basis of the change? I'm not suggesting that I'm 19 disagreeing. I just think that it needs to be defined,  :

l 20 since we are all aware that class 1 allowables are based on l I

21 the use of class 1 material fabrication examination i 22 techniques. So, I think this change is quite similar to l i

23 what the concerns I expressed are on attachment 1. We need I 24 to define how you walk through that. That's all. I 25 And I think that disconnect concern I had on the ACE-FEDERAL REPORTERS, INC.

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i 27973.0 50 BRT-1 l one slide may be appropriate to others. Therefore,  ;

2 whenever you talk about changes that are applicable to 3 class 2 and 3 piping and class-1, 2 and 3 supports, we make t

4 sure that in dealing with-the loads on the class 1 supports 5 that in fact the piping analysis is reflective of what you 6 propose for the supports. And that goes beyond just the .

7 one slide that we talked about. i 8 I asked a question earlier with respect to 9 attachment 1, and you said that someone.could go and audit 10 your consideration of the impact of other changes, for l 11 example in the winter 1978 addenda -- well, I picked a bad 12 one. , ,

13 In the winter 1976 addenda you pick paragraph 14 NC-31-13 and NC-36-49. I assume somewhere you have a ,

15 review of the winter '76 addenda that ends up saying:  ;

16 These two paragraphs are not dependent on any other changes t 17 that took place in the '76 addenda. And, if not, then I  !

I 18 would hope that you would have that so that that could be --

19 and that one, I guess, is easy. I i

i Some of them aren't so 20 Most of them are easy.

21 easy.

22 That's all I have. j i .

I just have one question that I  !

23 MR. TERAO:

l' l 24 would like, perhaps, Stone & Webster's definition of.

l 25 In accepting code case N-411, we had asked a i

l l

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1 l question regarding the need to revise the PSAR.

i 2 MR. NACE: The which?  ;

l 3 MR. TERAO: The PSAR. l ll In your letter of November 18, 1985, you stated I 5 that the damping values that you are proposing to use in 6 N-411 do not alter the principle architectural and j 7 engineering criteria. I would like to'know what your ,

i 8 definition, then, is of principal architectural and  ;

9 engineering criteria if it's not damping values.

10 MR. SISKIN: Would you like to answer that or --

11 MR. NACE: Go ahead.

12 MR. SISKIN: I would consider the principal j i

~13 values that would bring a change to the PSAR decision to go  !

i 14 from'a BWR to a PWR, a change in licensee. I think you'll l 1

15 find decisions.at that level are the kinds of changes that

'16 would warrant a PSAR. The whole concept that we have used l 17 l in this

industry for many years is that the SAR is a living f f

18 document and kept up to date with the evolution, and the i 19 concept of going back and revising a PSAR, after the fact >

20 on that, is totally foreign. i 21 MR. TERAO: I'm not asking you what would  !

22 constitute a change in the PSAR. I'm asking you a j 23 definition of a principal architectural and engineering l 24 criteria.

I' 25 MR. SISKIN: A very fundamental change. We are i

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-27973.0 52 BRT 1 talking about the change in the type of reactor. I'm not 2 talking about something of a much smaller scope than that.

3 Location, basically. Type of containment. Things that ,

4 would appear on a checklist when you are listing all the

.5 plants in the country, as to what the plants' basic 6 characteristics are. The decision to go from a 950 to a 7 much larger plant, although I can think of several cases l 8' where plants were upgraded substantially and the PSAR was 9 .not changed.

10 MR. TERAO: As a clarification, do you consider 11 any of the information presented in your slides today to be j 12 principal architectural or engineering criteria? j l

13 MR. SISKIN: Absolutely not.

14 MR. NACE: No.  ;

15 l MR. MI2UNO: As an attorney speaking, I commend i

16 to you this thought: That principal architectural and .

17 engineering criteria are required to be listed in the l 18 original application, the original PSAR. Before you 19 support the construction program. The point is that, if it j 20 had -- if something has to'be included in there in order i i

21 for an approval to be given, and any change to those types l 22 of things -- an initial legal view would be those are  ;

23 principal engineering and architectural changes. I 24 MR. NACE: That's preposterous. j i

25 MR. SISKIN: That really is preposterous. You  !

l, I I

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1 are saying if additional information is provided -- l 2 'MR. MIZUNO: I didn't say additional. I said 3 changed. I'm not setting down the legal -- law now. I'm j 4 just -- it's something for you to consider. If some l 5 principal engineering criteria, architectural and  ;

\

6 engineering criteria are required to be set forth --

7 MR. SISKIN: What is the legal contribution of l

8 precedent and practice in this entire situation?

i 9 MR. CHANDLER: Always very important, Ed. I 10 refer you to the Bailey case, Commission decision, 1979. l 11 Lengthy discussions about the length of piled. For your 12 information.

l 13 MR. MIZUNO: Which would be the kind of minor  !

i i

14 things which wouldn't require a change. j i

15 MR. NACE: It is our position there is no 16 fundamental change in these recommendations. No basis, no 17 requirement that we even consider what you suggested.

18 Furthermore, in my opinion, considering what you suggested i 19 is similar to requiring PSAR changes to submit the FSAR.

20 MR. SISKIN: Before you meddle with past 21 practice on very obtuse interpretations, I would recommend 22 that you look at the ramifications for every plant in the 23 country. Before you take that ridiculous position.

24 MR. CHANDLER: No one is meddling at this point, ,

i 25 Ed. It's just a concern that exists whenever changes are l

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i 27973.0 54 l BRT 1 made. That's.not a question that's simply limited to here.

2 MR. BAGCHI: Are you done? .

3 MR. TERAO: That's all I have. ,

4 MR. BAGCHI: I guess I have one thing to clarify.

i 5 You made a statement earlier on that all of these changes .

6 are going to make the plant safer. A lot of changes -- l 7 MR. SISKIN: Some of these changes will confirm 8 that the plant is safe.

9 MR. BAGCHI: I don't expect you to come 10 necessarily with an amendment which explains how that is.

11 However,-I think for our discussion, our approval of the 5

12 changes, it is relevant to know how some of the earlier i

13 discrepancies came about and how this is going to address 14 those deficiencies, if you like, which are going to go away l

i 15 as a result of this approval of the changes. {

16 MR. SISKIN: How it came about, I'm not in a .

17 position to answer. What we are doing, I am. l 18 MR. BAGCHI: Indicate how that is going to be 19 answered, and when? ,

20 MR. NOONAN: Well, let me get in on that. I  :

I 21 think what I want to do, for Stone & Webster -- you know, j i

22 you came in at a point and you see certain things at that l 23 point and that's documented. You know what you are

! 24 starting with, what you are finishing up with. I i

25 How we handle the part before that is a part I

i i  ;

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27973.0 55 BRT 1 that -- that's something we can go back to CPRT. That's a 2 CPRT question. We'll raise that.

I 3 MR. NACE: That's CPRT.

4 MR. BAGCHI: What I-was looking for is some kind 5 of a road map which says: These questions.are going to be ,

6 answered, this, that, and the other way. Prior approval --

7 it's rather important to know that information for our 4 8 approval.

9 MR. NOONAN: As soon as the Staff gets a chance t

10 to look at the package, and I'll look at these questions, i

11 I'll do a sort on it at our level here and then we'll i 12 decide which questions are really to the amendment package i i

13 and which questions go to the CPRT.

14 MR. NACE: Okay. j 15 MR. TRAMMELL: A question I had about sampling. l i

16 I heard that we were going to do a sampling of.small bore j t

17  ; piping. I haven't heard much about that in a long time.

18 But I missed a couple of these progress meetings.

19 Are we sampling small bore piping to decide 20 whether it's okay? Or are we going to go look at each one?  ;

I 21 MR. KLAUSE: What we are doing in the small bore I

i 22 effort is described in CPPP-15, which you have a copy of. l 23 It states what is actually included in the analysis for 24 small bore and what part of the small bore will be sampled. I 25 MR. NACE: The ultimate answer to your question  !

t 4

l l

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1 is it hasn't been decided yet because the sample itself 2 isn't concluded.

3 MR. TRAMMELL: You are sampling now and you ,

4 haven't decided what to do. Let's say you pass the sample. ,

5 Everything is hunky-dory. Who becomes the architect  ;

6 engineer of the piping system if the sample indicates  !

i 7 everything is okay?

8 MR. SISKIN: Stone & Webster is going to stand 9 behind the piping system. We are going to do whatever is ,

10 necessary to' stand behind the piping system.

4 11 MR. TRAMMELL: Would that mean you become the 12 engineer of record , based on a sample? 1 13 MR. KLAUSE: No. The way I understand it -- Ed 14 can correct me if I'm wrong - .but, for the analysis that 15 we do and perform for the small bore, we will be the l

16 architect of record for that. i i

17 ,

If everything shows that it's okay, then Stone &

18 Webster is in the position to say that the analysis done  ;

19 previously for those others are the analysis of record.

20 MR. NACE: You are mixing two questions, Charlie.

I 21 One is what is the documentation of record, and the other 22 is who is defending the design? The. charter we have given l 23 these people is to put themselves in a position of being 24 able to defend the design.

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1 percent of the documentation, it is their engineering 2 documentation. But the remaining documentation would be 3 whoever authored it as the record documentation. f 4 MR. NOONAN: I think Ron answered it fine. j 5 That's clear.  !

6 Has Staff'any other questions? l 7 MR. MIZUNO: I have an observation, not a j I

8 question. This really does not apply to Stone & Webster.

s 9 Actually it is directed to the applicants themselves.

10 Given the charter that is given to the 11 applicants currently to Stone & Webster, I believe that l 12 this is -- in fact, which is addressed to you, because we f i

13 have raised this earlier with Stone & Webster and they have l t

14 said this is not in our scope: Some of our questions you 15 have gathered are questions which reflect-the sensitivity, i

16 not just to the licensing process itself and whether l 17 something will be able to meet the standard Staff review 18 and concerns involved in changes to the operating license 19 application; we are also concerned, obviously, that l

20 whatever changes are made will be able to withstand a

! 21 scrutiny by the licensing board in the hearing. l l

l 22 Again, I would like to suggest something to you  !

i 23 to consider, which is that something which may be I i

24 acceptable from a technical -- a strict, technical I l

25 engineering standpoint, may not necessarily be sufficient l

l l

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27973.0 58 '

BRT 1 to withstand scrutiny in a licensing hearing.

2 Especially where the acceptability of a change j 3 may be more legalistic, as it were; in other words, j

- 4 something is permitted without an explicit engineering 5 reasoning cr justification for that -- something like that, t

6 based upon experience in our proceedings, has not worked in 7 .the past in terms of persuading the board. i i

8 Another thing, sort of a related question,.is 9 that, although technical questions may be answered in broad 10 scope by Stone & Webster, they are aware of it and they  !,

11 l have either addressed it or -- we just want to make the  ;

l

] 12' applicants aware that we are concerned that there may be l l

13 small' individual issues that may not be picked up, either  ;

14 by Stone & Webster or by the TERA effort. And that these  ;

I

15 ' individual issues be addressed in some fashion, j 16 MR. NACE
Such as?  !

17 MR. MIZUNO: In other words, we would say that 18 would not be appropriate for resolution through the Stone &  !

19 Webster requalification effort but we think that some f

20 applicant attention has to be given to that in order to 21 prevail at the hearing.

I 22 MR. CilANDLER: Let me give you an example of j 23 what Gary has in mind, to help you understand. i i

As a for example, I think it was Paul Chen asked l 24 I

25 earlier about the bolt hole issue. You have got one level l l

I ACE-FEDERAL REPORTERS, INC.

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27973.0 59

.BRT 1 of review and evaluation through the code, and what may or 2 may not satisfy the code requirements in terms of allowable  ;

3 bolt hole size.

4 Yet, a somewhat,different, very related issue,  !

5 was raised through the TRT and Staff review process earlier 6 on. A different issue was identified. Not simply one of 7 the acceptability of the bolt hele. l ,

8 MR. MIZUNO: And to expand upon that -- I .

I 9 MR. CHANDLER: There are two kinds of answers, 10 then, that are necessary to fully address the question. Or i 11 may be.necessary to answer the question. le 12 1: Is it technically acceptable? In terms of 13 compliance with the Commission's regulations and 14 requirements? And thus, is the plant safe? i 15 2: The related questions that were raised  !

I 16 through the TRT and other Staff inspection processes, of i>

l 17 which you have been aware.

J 18 For example, on bolt holes, that wasn't what the

! 19 original provisions allowed. How did that happen? What t l

20 allowed it to happen? I think that's what Gary had in mind.  !

l 21 MR. MIZUNO: That's one part.

22 MR. SISKIN: I understand what you are saying 23 and appreciate what Gary is saying as well.  !

! I 24 MR. MIZUNO: Let me say one more thing about the 25 example to expand on that apart from the TRT.

t ACE-FEDERAL REPORTERS, INC. '

202 347 3700 Nationside Coscrage BfMK33MM

1 27973.0 60 BRT 1 CASE's witnesses raise questions with the bolt 2 hole, not just because you violated a provision but they 3- have a reason for saying why was it something that you c i

! 4 could not forget? They had a technical reason, be it a 5 good -- a valid technical reasonable or invalid one is for ,

6 the Staff and the applicants to justify in front of the 7 board. But the point is that we -- if they presented a ,

8 technical reason for that, for their concern, that somehow 9 it has to be addressed. I'm not seeing that Stone & -

10 Webster's role in it, as a matter of fact, as I said, I "

- 11 think --

) 12 MR. NACE: That's a CPRT role. ,

j 13 MR. SISKIN: Gary, I don't disagree with what i 1

14 you are saying. All I'm asking, and what I was trying to i

15 say earlier, is let's at least keep the issues separated. i

! 16 Because some of these things get very clouded when you say:

i 17 Is it technically acceptable? That's one question. And  !

18 how can you get into it and what generic questions are 19 raised because of that is another question. If you mix I 20 them, you never get them settled. And -- i l

21 MR. CHANDLER: Gary's concern is let's not drop 22 the ball somewhere in the middle. Recognizing today we are l t  !

i 23 here to talk about what Stone & Webster is doing, I think 24 maybe the comments I have made and Gary and maybe Paul -- {

l i 25 MR. NACE: I heard, j

I I.
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i 1 MR. CHANDLER: Okay. I 2 MR. MIZUNO: That's why I directed it to 1

3 Mr. Nace, as opposed to Stone & Webster. l 4 MR. SISKIN: Back to an earlier point I made '

l 5 that I think is very important, too, it doesn't mean Stone i 6 & Webster won't be involved in some of these other ) a i

7 questions, but in order to keep the technical and other j j 8 separate, I would propose to do that. separate from the .

9 project.

10  ! MR. MIZUNO: That's fine. ,

i I

11 MR. NACE: The purpose here was to give you l-

, 12 bases for the work they are doing, such that, regardless of i ,

j i i

- f .i

! 13 other questions you have, at the point in time they are I 6 finished with the requalification effort, when wa all know i 14

} 15 ' that the piping system is going to perform their intended

  • i l

16 safety function, period. i f 17 MR. NOONAN: Okay. ,

I 18 l MR. MIZUNO: All right.

19 MR. TRAMMELL: At the beginning you said that i

! 20 every change that is intended or known today has been ,

i  !

21 identified here at this meeting. It seems to me that you ,  ;

i ,

1 i 22 are so close to the end of the process that you might be ,

t 1 '

23 very close to being -- telling us this is all.

4 24 MR. NACE: It may be.

l I

25 MR. TRAMMELL: When does the other choe fall?  ! >

' I I I  !

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j 1 In a month from now? Will you know when you submit this 4

2 ' application for proposed change? At wha't point will we l

[

t l 3 know this is all?  ! ~

4 MR. NACE: I don't know, Charlie. It's just.  ;

! 5 like any nuclear design job, it's all when you are done. l 1 .  :

6 Where they stand on unit 1, 315 out of 317 j l'

! 7 stress problems are done except for confirmation-type l '

' l

!, 8 activities. About close to 7000 of the supports have been 9 requalified with changes identified. So that says there's I 1 10 about 3000 more supports to go, and two stress problems ou ,

11 unit 1. I j

12 j Unit 2 stress is -- -

I t 13 i MR. KLAUSE: Essentially just beginning, as far i  ;

I i 14 as 100 percent confirmation. It has been the 8 percent i ,

15 effort going right along. i I

l 16 MR. NACE: I don't think you are going to see l' L

{ 17 another meeting in another month. But I can't promise you. i 18 MR. TRAMMELL: Before we close, I would like to f.

l

! 19 give the intervenor, CASE, Adam Palmer, a chance to make i i b

! I j 20 any remarks you may have if you have any. I

< I [

i 21 MR. PALMER: I have one question. Yes, one .

1 22 question I have is: What information did you use that you j t

1 23 relied upon to determine that you needed to change the code?  !

[

I t j 24 That you needed an amendment? CASE doesn't understand ,

j >

r

{ 25 ,

where you get your information that there needs to be a  ! t l \ r r r 4 i <

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i i 27973.0 63  !'

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1 I change? j 2 MR. KLAUSE I think one of the slides I showed 3 up there addressed that, that identified the changes  !

4 required to meet the methodology that we normally use. l 5 Also, changes that were made to meet _the intent of the i 6 regulatory position in NUREG-0800, and then the other I 7 changes required for clarification where it was not clear  ;

8 or specific in the FSAR.

I 9 MR. PALMER: Did you use CPRT7 Or independent 10 analysis? Where specifically? What information did you 11 rely upon that said this is wrong, we need to change it? l i

Let me try to answer that, Ron, and 12 j MR. NACE: l 13 then you can say if I'm correct or not. They start out

, (

14 with an SAR that has a set of words in it. They also start  ;

15 out over here with a Stone & Webster standard practice that 16 { has evolved over the course of years and has been used to- l 17 llicenserecentplants. You identify the dif ferences. ,

i 18 MR. CHANDLER: I didn't mean to interrupt you i, 19 '

but you all got some discovery ongoing. I'm not sure how '

I 20 this relates to it or if it does relate to it. I don't t

21 know -- I don't see their counsel here right now. I guess, 22 in fairness to them, if you've got questions, why don't you l

23 ask them so we get them out on the record. Maybe it would l 24 be best if they took those questions home and got back to l.

25 you in a formal response, rather than trying to answer them f i

i 1 ,

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l 1 lnowandget their lawyers all upset and exercised over .

2 something. .

i  ! ,

3 l MR. PALMER: That was my only question. .

4 MR. CHANDLER: Okay. i l 5 , MR. PALMER: On behalf of Juanita Ellis, she il z

l I

I 6 I

would like you to send the transcripts as soon as possible, i 5

i

7 preferably when the Staff gets theirs.

i' I I 8 MR. TRAMMELL: We get 24-hour service.  !

i i j 9 j MR. HOONAN: Billy Bob's checklist is in the [

10  ; mail. If you want to pick one up there, you can get.it.  !

4 I

! 11  ! I'm finished. Thank you very much.

,. i, ,

i 12 i (Whereupon, at 11:30 a.m., the meeting was ,;

! 13 adjourned.) [

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CERTIFICATE OF OFFICIAL REPORTER

l.

t This is to certify that the_ attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the

! matter of:

J NAME OF PROCEEDING: COMANCHE PEAK REANALYSIS OF PIPING AND

PIPE SUPPORT BY STONE AND WEBSTER DOCKET NO.

i PLACE: BETHESDA, MARYLAND  !

t DATE: THURSDAY, AUGUST 28, 1986 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission.

f i

I (sigt)

(TYPE

, , /.

o t

i BREITNER i JO Official Reporter  ;

' ACE-FEDERAL REPORTERS, INC. [

! Reporter's Affiliation i i

I 4

t 4

-l AGENDA .l i TUGCO PRESENTATION TO THE NRC t

AUGUST 28,1986

)

A. INTRODUCTION L.D. NACE, TUGCO B. SWEC OVERVIEW E.J. SISKIN, SWEC C. SWEC PRESENTATION R.P. KLAUSE, SWEC

1. FSAR UPDATES FOR PIPING REQUALIFICATION PROGRAM l lI. ASME CODE EDITIONS, ADDENDA, AND CODE CASES USED FOR THE PIPING REQUALIFICATION PROGRAM _ ,,,,,

L __ _ - . .- _

~l SWEC PRESENTATION

1. FSAR UPDATES FOR PIPING ~

REQUALIFICATION PROGRAM ll. ASME CODE EDITIONS, ADDENDA, AND l CODE CASES USED FOR THE PIPING l REQUALIFICATION PROGRAM _ ....

l l

l

-l

l. UPDATING COMANCHE PEAK (CPSES)

UNITS 1 AND 2 FSAR PIPING SYSTEM REQUALIFICATION PROGRAM OBJECTIVES:

e TO ASSURE FSAR ACCURATELY REFLECTS THE SWEC DESIGN METHODOLOGY e TO INCLUDE THE SWEC COMPUTER PROGRAMS USED FOR PIPING SYSTEM REQUALIFICATION PROGRAM IN

! THE FSAR e TO UPDATE THE FSAR FOR THE PIPING SYSTEM REQUALIFICATION PROGRAM TO MEET THE INTENT OF USNRC STANDARD REVIEW PLAN NUREG-0800. . . . . . .

1 TOPICS INC~LUDED IN THE

UPDATE i

) .

! CURRENT

! SWEC REGULATORY CLARIFICATION TOPICS ' METHODOLOGY POSITIONS OR ADDITION i

l 1. COMPUTER PROGRAMS X l 2. SSE LOADING IN EMERGENCY X X PLANT CONDITION .

3. SEISMIC RESPONSE IN ZPA X X l REGION '
4. COMBINATION OF PEAK X X i DYNAMIC RESPONSES i 5. PLASTIC ANALYSIS X X i
6. FUNCTIONAL CAPABILITY X X
7. SPECTRAL BROADENING & X DAMPING VALUES

! 8. STRESS CYCLES X X l 9. MISCELLANEOUS UPDATES X X

10. ASME CODE OF RECORD X j . . . . .

i ,

5

4

! 1. COMPUTER PROGRAMS UTILIZED 1

PROPOSED CHANGE:

TO SPECIFY IN THE FSAR THOSE COMPUTER PROGRAMS WITH THElR VERIFICATION THAT ARE UTILIZED BY SWEC IN THE PIPING SYSTEM REQUALIFICATION PROGRAM.

REASON FOR CHANGE:

UPDATE THE LIST OF COMPUTER PROGRAMS USED FOR ANALYSIS OF PIPING SYSTEMS.

BASIS FOR CHANGE:

TO CONFORM TO GUIDANCE IN NUREG-0800, SECTION 3.9.1, SUBSECTION l1.2.

APPLICATIONS:

ASME CODE CLASS 2 AND 3 PIPING SYSTEMS INCLUDING SUPPORTS FOR hSNIE CODE CLASS 1,2, AND 3 PIPING (APPENDIX 3B OF FSAR).

L

COMPUTER PROGRAMS PREVIOUSLY UTILIZED .

ON OTHER DOCKETS RIVER NINE MILE BEAVER MILLSTONE COMPUTER PROGRAM BEND 2 VALLEY 2 3 SHOREHAM NUPIPE-SW X X X X X BAP X X e BSPLT *

  • STARDYNE X X e X e PITRUST X X X X X PILUG X X X X X PITRIFE *
  • X X X STEHAM X X X X X WATHAM X X X X X WATSLUG X X ELBOW X e PSPECTRA X X X X
STRUDL-SW X X X X X STRUDAT AND SANDUL e e

! BASEPLATE-Il e o X e e BIP X

  • X
  • l APE
  • X X
  • CHPLOT

! RELAP e e e e o

i

2. SSE LOADING COMBINATIONS .

! PROPOSED CHANGE:

i DELETE SSE FROM LOADING COMBINATIONS IN EMERGENCY PLANT ,

CONDITIONS (SERVICE LEVEL C).

REASONS FOR CHANGE:

e TO CONFORM WITH TABLE 1, APPENDIX A, NUREG-0800,(JULY,1981)

I e TO BE CONSISTENT WITH NSSS (CLASS 1) LOADING COMBINATIONS e TO BE CONSISTENT WITH SWEC METHODOLOGY ON MORE THAN 8 OTHER DOCKETS l BASIS FOR CHANGE:

i PRESENT VERSION OF FSAR CONSIDERED SSE IN PLANT EMERGENCY CONDITION FOR BOP SYSTEMS. IT WAS BASED UPON REGULATORY GUIDE 1.48 (MAY,1973) POSITION FOR CLASS 2 AND 3 PIPING.

l NUREG-0800, SECTION 3.9.3, APPENDIX A, SUBSECTION 4.2 l STATED " APPENDIX A REQUIREMENTS SUPERSEDE THOSE IN THE l MAY 1973 VERSION OF REGULATORY GUIDE 1.48".

l APLICATIONS:

j ASME SECTION 111 CLASS 2 AND 3 PIPING SYSTEMS AND CLASS 1, 2, AND 3 PIPE SUPPORTS (SECTION 3.9B.1.1,3.9B.3.1, TABLES '

3.9B-1B AND 3.9B-1C OF FSAR).

1

3. SEISMIC RESPONSE IN ZPA REGION I PROPOSED CHANGE:

ADD THE METHOD IN NUREG/CR-1161 (DECEMBER,1979) TO RESPONSE ,

SPECTRUM ANALYSIS OF PIPING SYSTEMS TO ADDRESS HIGH FREQUENCY SEISMIC RESPONSES IN THE 7.ERO PERIOD ACCELERATION (ZPA) REGION OF THE SPECTRA (ARS).

REASON FOR CHANGE:

  • THE EXISTING FSAR IS SILENT ON THIS ISSUE.

BASIS FOR CHANGE:

e TO ASSURE PARTICIPATION OF ALL SIGNIFICANT MODES IN RESPONSE SPECTRUM ANALYSIS OF PIPING SYSTEMS.

APPLICATIONS:

ASME CODE CLASS 2 AND 3 PIPING SYSTEMS,(SECTION 3.7B.3.1 OF FSAR). ,,, ,,,,

l

4. COMBINATION OF PEAK DYNAMIC RESPONSES -
PROPOSED CHANGE

PEAK DYNAMIC RESPONSES OF PIPING SYSTEMS DUE TO SEISMIC, LOCA, AND/OR OCCASIONAL LOADS ARE COMBINED BY THE SQUARE ROOT OF THE SUM OF SQUARES (SRSS) TECHNIQUE.

REASONS FOR CHANGE:

e UPDATE TO BE CONSISTENT WITH SWEC METHODOLOGY ON MORE THAN 8 OTHER DOCKETS

, e MINIMlZE PLANT MAINTENANCE THEREBY REDUCING PERSONNEL EXPOSURES (ALARA) i e TO BE CONSISTENT WITH NSSS (CLASS 1) METHODOLOGY BASIS FOR CHANGE:

e SRSS COMBINATION OF SSE AND LOCA RESPONSES IS IN CONFORMANCE WITH NUREG-0484 (MAY 1980).

o SRSS PROCEDURE OF COMBINING WATER HAMMER EVENTS (OCCASIONAL LOADS) WITH EARTHQUAKES AND PLANT DYNAMIC EVENTS IS AN ACCEPTABLE METHOD IN NUREG-1061 (VOLUME 4, JANUARY 1985).

APPLICATIONS-ASME CODE CLASS 2 AND 3 PIPING SYSTEMS AND CLASS 1,2, AND 3 PIPE SUPPORTS (SECTIOI 3.9B.3.1 OF FSAR). ,,,,,.,,,,

l

5. PLASTIC ANALYSIS PROPOSED CHANGE: i REVISE PARAGRAPH 3.9B.1.4.1 TO INCLUDE THE OPTION PERMITTED BY

! THE CODE TO USE PLASTIC ANALYSIS FOR ASME CODE CLASS 2

! AND 3 COMPONENTS.

i REASON FOR CHANGE:

TO PROVIDE A BASIS FOR THE QUALIFICATION OF CLASS 2 AND 3 PIPING FOR LOCAL EFFECTS BASIS FOR CHANGE

IT IS APPROPRIATE TO USE THE CODE CLASS 1 APPROACH IN NB-3228 TO EVALUATE THESE LOCALIZED EFFECTS.

APPLICATION:

ASME CODE CLASS 2 AND 3 PIPING SYSTEMS FOR LOCAL STRESS l EVALUATION BETWEEN PIPE AND SUPPORT MEMBERS. c ... m.

6. FUNCTIONAL CAPABILITY PROPOSED CHANGE:

ADD FUNCTIONAL CAPABILITY ASSURANCE REQUIREMENTS FOR PIPING SYSTEMS BY THE ANALYTICAL CRITERIA IN NEDO-21985 (SEPTEMBER,1978) AND RELATED DOCUMENTS. IN ADDITION, THE STRESS LIMITS FOR ESSENTIAL SYSTEMS (FSAR TABLE 3.98-1B) HAVE BEEN REVISED.

REASONS FOR CHANGE:

e TO ASSURE OPERABILITY OF ESSENTIAL PIPING SYSTEMS DURING AND AFTER A POSTULATED PLANT ACCIDENT CONDITION.

e TO CONFORM WITH THE REGULATORY POSITION C.2.3 IN APPENDIX A, SECTION 3.9.3, OF NUREG-0800 (APRIL,1984).

BASIS FOR CHANGE:

l THE PROPOSED ANALYTICAL CRITERIA TO ASSURE THE FUNCTIONAL i CAPABILITY REQUIREMENTS MEET THE OBJECTIVES OF NUREG-0800.

! APPLICATIONS:

ASME CLASS 2 AND 3 PIPING SYSTEMS TO BE OPERATIONAL DURING i

AND AFTER A POSTULATED PLANT ACCIDENT CONDITION (SECTION 3.98.3.1.2 OF FSAR). ,,,,,,,

7. SPECTRAL BROADENING (CC-N-397) -

AND DAMPlNG VALUES (CC-N-411)

PROPOSED CHANGE:

APPLY ALTERNATIVE RULES TO THE SPECTRAL BROADENING AND DAMPING VALUES IN ASME CODE CASES N-397 AND N-411 i RESPECTIVELY.

REASON FOR CHANGE:

UPDATE TO INCLUDE APPROVED ALTERNATIVE RULES.

BASIS FOR CHANGE

) e NRC LETTER FROM V.S. NOONAN TO W.G. COUNSIL, DATED MARCH 13,1986.

e TUGCO LETTER FOR W.G. COUNSIL TO V.S. NOONAN, DATED NOVEMBER 18,1985.

e HIGHLY RESEARCHED APPROACH UTILIZED ON MORE THAN 20 PLANTS APPLICATIONS:

I e ASME CODE CLASS 2 AND 3 PIPING SYSTEMS ANALYZED BY

) RESPONSE SPECTRUM METHODS. ce.. . m 1- -- - - - - -

~

8. STRESS CYCLES FOR SEISMIC EVENT i

PROPOSED CHANGE:

SPECIFY A MINIMUM OF 50 MAXIMUM AMPLITUDE LOADING CYCLES FOR THE FIVE OBE EVENTS AND 10 MAXIMUM AMPLITUDE LOADING

CYCLES FOR THE SSE EVENT.

t REASON FOR CHANGE:

j TO BE CONSISTENT WITH SWEC METHODOLOGY ON OTHER DOCKETS AND TO CONFORM WITH CURRENT REGULATORY ACCEPTANCE CRITERIA.

BASIS FOR CHANGE:

NUREG-0800, SECTION 3.7.3, SUBSECTION ll.2.B: AND SECTION 3.9.2, SUBSECTION ll.2.B.

APPLICATION:

ASME CODE CLASS 2 AND 3 PIPING SYSTEMS COMPONENTS (SECTION 3.78.3.2 OF FSAR). ,,,,,,,

e i

9. OTHER FSAR UPDATES .

PROPOSED CHANGES: -

e UPGRADE VALVE MODELING TECHNIQUE IN SECT!ON 3.7B.11.

! e ADD CONTAINMENT DISPLACEMENT LOAD COMBINATIONS IN TABLES 3.9B-1B,3.98-1C, AND 3.9B-1E.

l e ADD THERMAL AND SEISMIC ANCHOR DISPLACEMENT LOADING COMBINATIONS FOR SYSTEMS WHOSE NORMAL OPERATION IS i REQUIRED IN FAULTED CONDITION, TABLE 3.9B-1B.

e ADD STRESS LIMITS FOR SUPPORTS FOR SYSTEMS WHOSE NORMAL OPERATION IS REQUIRED IN FAULTED CONDITION, TABLE 3.9B-1E.

e UPGRADE THE FLUID TRANSIENT ANALYSIS METHODS FOR PRESSURE j RELIEVING DEVICES IN SECTION 3.9B.3.3, IN CONFORMANCE WITH APPENDIX 0 OF ASME SECTION lil CODE.

REASON FOR CHANGES:

UPGRADE THESE SECTIONS OF FSAR TO REFLECT SWEC DESIGN CRITERIA OF PIPING SYSTEM REQUALIFICATION PROGRAM.

! BASIS FOR CHANGES:

THESE CHANGES ARE ADDITIONS OR UPGRADES OF THE DESIGN l

PROCEDURES FOR COMPLETENESS AND TO BE CONSISTENT WITH THE INTENT OF NUREG-0800.

l APPLICATIONS:

ASME CODE CLASS 2 AND 3 PIPING SYSTEMS AND CLASS 1,2, AND 3 PIPE SUPPORTS.

10. ASME CODE OF RECORD PROPOSED CHANGE:

TO STATE THAT ASME SECTION ill,1974 EDITION INCLUDING SUMMER l

1974 ADDENDA SUBSECTIONS NC, ND, AND 1974 EDITION INCLUDING l

WINTER 1974 ADDENDA SUBSECTION NF IS THE ASME CODE EDITION OF RECORD.

REASON FOR CHANGE:

TO CLARIFY THE CODE OF RECORD.

BASIS FOR CHANGE:

NOT APPLICABLE APPLICATIONS:

ASME CODE CLASS 2 AND 3 PIPING SYSTEMS AND CLASS 1,2, AND 3 PIPE SUPPORTS. ce.....,,

i

F ASME CODE EDITION PARAGRAPHS AND CODE CASES e AS PERMITTED BY PARAGRAPH NA-1140 OF THE 1974 EDITION OF THE CODE, SPECIFIC PARAGRAPHS IN MORE RECENT EDITIONS AND ADDENDA OF THE ASME CODE HAVE BEEN INVOKED. THESE ARE SHOWN IN ATTACHMENT 1.

  • ASME CODE CASES UTILIZED ARE SHOWN IN ATTACHMENT 2. . .......

4 ATTACHMENT 1 ASME BOILER AND PRESSURE VESSEL CODE, SECTION lil, DIVISION 1 NUCLEAR POWER PLANT COMPONENTS:

1974 EDITION - SUMMER 1974 ADDENDA SUBSECTION NB - FOR EVALUATION OF NOZZLE STIFFNESS, QUALIFICATION OF ELBOWS WITH BRANCH CONNECTIONS, AND FUNCTIONAL CAPABILITY.

1974 EDITION - WINTER 1976 ADDENDA PARAGRAPH NC-3113 - SERVICE CONDITIONS AND PARAGRAPH NC-3649- FOR EVALUATION OF FLEXIBLE HOSE.

1977 EDITION - WINTER 1978 ADDENDA, APPENDIX 0 - FOR EVALUATION OF SAFETY RELIEF VALVES.

l 1977 EDITION - WINTER 1978 ADDENDA, PARAGRAPHS XVil-2211 AND l NF-3226.5, NF-3321.1, AND FIGURES NF-3226.5-1 AND XVil-2211(c)-1. ,

! 1977 EDITION - WINTER 1979 ADDENDA, PARAGRAPH XVil-2454(c). /

1980 EDITION, PARAGRAPHS NF-1131.6, NF-1133, AND XVil-2462.

1980 EDITION - WINTER 1982 ADDENDA, PARAGRAPHS NF-3225.1, NF-3225.2, NF-3324.5(A), NF-3324.6(A), AND TABLES NF-3225.2-1 AND

NF-3324.5(D)(1)-1.

1983 EDITION, PARAGRAPH NC-3658.3 - FOR FLANGE QUALIFICATION,

PARAGRAPH NC-3673 - FOR BRANCH CONNECTION QUALIFICATION.

1983 EDITION - SUMMER 1985 ADDENDA, PARAGRAPH NF-4721 - BOLT HOLES. ,,,,,,,,,

i

4 ATTACHMENT 2 ,

LISTED IN UTILIZATION CODE REG. GUIDES REQUIRED TO BE CASES 1.84 OR 1.85 SHOWN IN FSAR N-71-9 (1644-9) YES NO N-224 YES NO j N-225 YES NO N-247 YES NO

N-249-3 YES NO N-253-4 (NOTE) NO -

N-318-2 YES YES N-392 YES NO j N-397 YES YES N-411 YES YES N-413 YES NO

, N-1606-1 YES NO

N-1724 YES NO j N-1734 YES NO NOTE: REQUEST FOR SPECIFIC NRC APPROVAL IS IN PROCESS.

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