ML20212M405

Forwards Comments on 860915 & 1010 Proposed FSAR Changes Re Pipe Break Criteria.Damping Values from ASME Code Case N-411 May Only Be Used in Analyses Assuming Upper Bound Envelope of Response Spectra.Addl Info Re Seismic Analysis Requested

ML20212M405
Person / Time
Site:	South Texas
Issue date:	01/16/1987
From:	Kadambi N Office of Nuclear Reactor Regulation
To:	Goldberg J HOUSTON LIGHTING & POWER CO.
References
NUDOCS 8701300112
Download: ML20212M405 (7)

Text

. . .

Docket Nos.: 50-498 and 50-499 Mr. J. H. Goldbera Group Vice President, Nuclear Houston 1.iahting & Power Company P.O. Box 1700 $

Pouston, Texas 77001

SUBJECT:

NRC STAFF COMMENTS AND RE00EST FOR ADDITIONAL. INFORMATION ON CERTAIN PIPE BREAK CRITERIA APPL.IED AT SOUTl* TEXAS References 1. I.etter from M.R. Wisenburg to V. Noonan,

" Additional Annotated FSAR Changes Con-cerning Section 3.6 Pipe Break Criteria",

dated September 15, 1986

2. I.etter from M,R. Wisenburo to V. Noonan, (

" Additional Information Concerning L Section 3.6 Pipe Break Criteria", dated October 10, 1986 {

3. I.etter from V. Noonan to 0. Goldbera, "The South Texas Proiect Request for Approval on Use of Increased Cumulative Usaae Factor",

dated December 31, 1986.

The staff has reviewed References 1 and 2 in which several changes to Section 3.6 of the South Texas FSAR were proposed. The enclosure provides the staff's comments as a result of this review and also requests information in the area of seismic analysis. The comments are self-explanatory and make reference to the above correspondence.

If you have any auestions, please contact me at (301) 49?-7272.

N. P. Kadambi, Project Manager Project Directorate No. 5 Division of rWR I.icensing-A cc: See next pace

Enclosure:

As stated Distribution Docket File V. Noonan 0GC in Pothesda E. Jordan NRC POR I.ocal PDP PD#5 R/F V. Noonan 0GC Pethesda E. Jordan P. Grimes J. Partlow N. Thompson N. Kadambi

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V Docket Nos.: 50-498 and 50-499 Mr. J. P. Goldbero Group Vice President, Nuclear Houston I.ighting & Power Company P.O. Box 1700 Pouston, Texas 77001

SUBJECT:

NRC STAFF COMMENTS AND REQUEST FOR ADDITIONAL. INFORMATION ON CEPTAIN PIPE BREAK CRITERIA APPL.IED AT SOUTP TEXAS References 1. I.etter from M.R. Wisenburo to V. Noonan,

" Additional Annotated FSAR Chances Con-cerning Section 3.6 Pipe Break Criteria",

dated September 15, 1986

2. I.etter from M.R. Wisenburg to V. Noonan,

" Additional information Concernino Section 3.6 Pipe Break Criteria", dated October 10, 1986,

3. I.etter from V. Noonan to 0. Goldberg, "The South Texas Pro.iect Reouest for Approval on Use of increased Cumulative Usage Factor",

dated December 31, 1986.

The staff has reviewed References 1 and 2 an which several chances to Section 3.6 of the South Texas FSAR were proposed. The enclosure provides the staff's comments as a result of this review and also reouests information in the area of seismic analysis. The comments are self-explanatory and make reference to the above correspondence.

If you have any questions, please contact me at (301) 492-7272.

N. P. Kadambi, Project Manager Protect Directorate No. 5 Division of PWR I.icensing-A cc: See next page

Enclosure:

As stated Distribution Docket FiTI V. Noonan OGC in Bethesda E. Jordan NRC PDR I.ocal PDR , PD#5 R/F V. Noonan OGC Pethesda E. Jordan B. Grimes l J. Partlow N. Thompson N. Vadambi M. Rushbrook ACRS (101 PD#5 DIR:PD#5 NKadambi:ss VSNoonan 1/ /87 1/ ,/87

gm49'o,, UNITED STATES

, ,8 g NUCLEAR REGULATORY COMMISSION y ;E WASHINGTON, D. C. 20555

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JAN .16 fgn7 1 Docket Nos.: 50-498 and 50-499 Mr. J. H. Goldberg Group Vice President, Nuclear .

Houston I.ighting & Power Company P.O. Box 1700 Houston, Texas 77001

SUBJECT:

NRC STAFF COMMENTS AND RE0 VEST FOR ADDITIONAL. INFORMATION ON CERTAIN PIPE BREAK CRITERIA APPL.IED AT SOUTH TEXAS References 1. I.etter from M.R. Wisenburg to V. Noonan,

" Additional Annotated FSAR Changes Con-cerning Section 3.6 Pipe Break Criteria",

dated September 15, 1986

2. I.etter from M.R. Wisenburg to V. Noonan,

. " Additional Information Concerning Section 3.6 Pipe Break Criteria", dated October 10, 1986. -

3. I.etter from V. Noonan to 0. Goldbero, "The South Texas Project Request for Approval on Use of Increasod Cumulative Usage Factor",

dated December 31, 1986.

The staff has reviewed References 1 and 2 in which several changes to Section 3.6 of the South Texas FSAR were proposed. The enclosure provides the staff's comments as a result of this review and also requests information in the area of seismic analysis. The comments are self-explanatory and make reference to the above correspondence.

If you have any questions, please contact rre at (301) 492-7?72.

/ ht u ' u cw([

N. . Kadambi, Project Manager Project Directorate No. 5 Division of PWR I.icensing-A cc: See next page

Enclosure:

As stated

s Mr. J. P. Goldberg Houston lighting and Power Company South Texas Pro. ject cc: i Brian Berwick, Esq. Resident Inspector / South Texas Assistant Attorney General Pro.iect Environnental Protection Division c/o U.S. Nuclear Regulatory Commission P. O. Box 12548 P. O. Box 910 Capitol Station Bay City, Texas 77414 Austin, Texas 78711 Mr. Jonathan Davis Mr. J. T. Westermeir Assistant City Attorney Manager, South Texas Pro.fect City of Austin Houston L.ighting and Power Company P. O. Box 1088 P. O. Box 1700 Austin, Texas 78767 Pouston, Texas 77001 Ms. Pat Coy Mr. P. L. Peterson Citizens Concerned About Nuclear Mr. G. Pokorny Power City of Austin 5106 Casa Oro P. O. Box 1088 San Antonio, Texas 78233 Austin, Texas 78767 Mr. Mark R. Wisenberg Mr. J. B. Poston Manager, Nuclear licensing Mr. A. Von Rosenberg Pouston lighting and Power Company City Public Service Boad P. O. Box 1700 P. O. Box 1771 - Houston, Texas 77001 San Antonio, Texas 78296 Mr. Charles Falligan Jack R. Newman, Esq. Mr. Burton L. Lex Newman & Poltzinger, P.C. Bechtel Corporation 1615 t. Street, NW P. O. Box 2166 Washington, D.C. 20036 Pouston, Texas 77001 Melbert Schwartz, Jr., Esq. Mr. E. R. Brooks Baker & Botts Mr. R. L. Range One Shell Plaza Central Power and light Company Houston, Texas 77002 P. O. Box 2122 Corpus Christi, Texas 78403 Mrs. Peggy Buchorn l Executive Director

Citizens for Equitable Utilities, Inc.

Route 1, Box 1684

Brazoria, Texas 77422 l

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. o Houston lighting & Power Company -

2- South Texas Pro. ject i

cc:

Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Office of Executive Director

.for Operations 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Mr. lanny Sinkin, Counsel for Intervenor Citizens Concerned about Nuclear Power, Inc.

, Christic Institute 1324 North Capitol Street Washington, D.C. 20002 licensing Representative Pouston lighting and Power Company Suite 1309 7910 Woodmont Avenue Bethesda, Maryland 20814 E

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ENCLOSURE STAFF COMMENTS ON PIPE BREAK CRITERIA

1. In Reference 1, page ? of 38, the applicant has revised its response to staff Question 210.19 N by adding its letter ST-HL-AE-1723 dated August 28, 1986. This letter requests that additional systems be added to the applicant's original request to eliminate certain arbitrary intermediate pipe breaks. The applicants original request was submitted in letters dated August 20, 1984 and l' arch 8,1985. In a letter to the applicant dated August 13, 1985, the staff approved this reouest, and restricted the approval to only those systems inc'luded in the original request. The latest request, however, is under review by the staf f and is scheduled for completion by January 30, 1987.

2. In Reference 1, page 12 of 3a the applicant has proposed an insert which states that 12" and larger piping connected to the RCL may be modeled with the RCL in the same piping analysis and, therefore, considered as a part of the main run. The applicants' letter ST-HL-AE-1775 dated October 10, 1986 (Reference 2) provides a technical justification for this coupled analysis.

The staff has concluded that use of the coupled analysis concept is acceptable. However, the last paragraph in the October 10, 1986 letter states that the seismic analysis perfomed in this study used the multiple support input response spectra method with combination of support groups by the absolute sum method together with the increased damping values from ASME Code Case N-411. The current staff position is that damping values from Code Case N-411 may be used only in analyses which assume an upper bound envelope of the individual response spectra for all support locations to calculate maximum inertial response of multiply-supported items. This position had been taken during the review of several recent plants which requested use of code Case N-411. The basis for this position is also documented in Regulatory Guide 1.84, " Design and Fabrication Code Case Acceptability ASME Section III, Division 1", Revision 24, dated June, 1986. This revision states that Code Case N-411 is acceptable provided that use of the damping values in the Code Case is limited only to response spectrum analyses similar to the analysis used in NUREG/CR-3526, " Impact of Changes in Damping and Spectrum Peak Broadening on the Seismic Response of Piping Systems." The Standard Review

, Plan, Section 3.9.2 guidance, i.e. an upper bound envelope response spectrum, l was used as input to the piping system analyses which are discussed in NUREG/CR-3526. Therefore, the staff cannot currently accept the use of Code Case N-411 damping values with the multiple support input response spectrum method without further justification. An acceptable basis for such justification would be to perform a study calculation on each applicable piping system. These calculations should either:

a. Use the multiple support input response spectra method with combination of support groups by the absolute sum method together l

with Regulatory Guide 1.61 damping, or

b. Use the upper bound envelope response spectra method together with Code Case N-411 damping values.

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The results of 1 or 2 above should satisfy the following criteria:

a. All applicable FSAR allowable stresses should be satisfied.

b. The existino support configuration for each piping system should be adequate, ie., no supports should be moved, redesigned, or over-stressed.

3. In Reference 1, page 14 of 38 the applicant proposed Insert C which states that for ASME Class 1 austenitic stainless steel piping, breaks are postulated when the cumulative usage factor exceeds 0.4. Reference 3 provided the staff's evaluation of the applicent's request to increase the cumulative usage factor threshold from 0.1 to 0.4 The conclusions in this evaluation were based on system specific information; therefore, use of the 0.4 factor as referenced in the proposed Insert C is not acceptable.

I