ML20245G042
| ML20245G042 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/01/1989 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19297H611 | List: |
| References | |
| IEB-88-011, IEB-88-11, TXX-89228, NUDOCS 8905030058 | |
| Download: ML20245G042 (6) | |
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~::::ll E Log # TXX-89228 File # 10119 clo r
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903.6 Ref. # NRCB 88-11 1UELECTRIC May 1, 1989 5']$<*v'!Ia erasisan V. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 NRC BULLETIN 88-11:
PRESSURIZER SURGE LINE THERMAL STRATIFICATION AND LEAK-BEFORE-BREAK-QUALIFICATION FOR COMANCHE PEAK UNIT 1 Gentlemen:
TV Electric has completed a plant-specific analysis of the effects of thermal stratification on the Comanche Peak Unit 1 Pressurizer Surge Line (Surge Line) in accordance with the requirements of Action 2a of NRC Bulletin 88-11.
The analysis shows that there is no effect on the Surge Line integrity or the ability to satisfy leak-before-break criteria.
The analysis concludes that the design life (forty years) and ASME III Code compliance are not affected.
This letter provides the plant specific analysis in a total of two attachments and three enclosures.
The first attachment provides the required affidavit in accordance with the reporting requirements of NRC Bulletin 88-11 that responses be submitted under oath or affirmation under the provisions of section 182a, Atomic Energy Act of 1954, as amended. The second attachment provides a chronology of leak-before-break methodology considerations of TV Electric's request for approval of leak-before-break applications to the reactor coolant loop branch lines (specifically, Pressurizer Surge Line, Residual Heat Removal and Accumulator Injection Lines).
The first enclosure consists of five (5) copies of WCAP-12248, entitled
" Evaluation of Thermal Stratification For The Comanche Peak Unit 1 Pressurizer Surge Line" (Proprietary).
The second enclosure consists of five (5) copies of WCAP-12247, entitled
" Evaluation of Thermal Stratification For The Comanche Peak Unit 1 Pressurized Surge Line" (Non-Proprietary).
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The third enclosure consists of a Westinghouse Application for Withholding, CAW-89-062, Accompanying Affidavit, CAW-88-129, and Proprietary Information Notice.
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TXX-89228 May 1, 1989
.Page 2 of 2 As this submittal contains information proprietary to Westinghouse E'iectric l
Corporation, it is supported.by an affidavit signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10CFR2.790.
Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10CFR2.790.
Correspondence with respect to the proprietary aspects of the Application for Withholding should reference CAW-89-062 or the supporting Westinghouse affidavit should reference CAW-88-129 and be addressed to R. A.
i Wiesemann, Manager Regulatory and Legislative Affairs, Westinghouse Electric Corporation, P. O. Box 355, Pittsburgh, Pennsylvania 15230.
The remaining action required by Bulletin 88-11 Action 2a is to assess Hot Functional Test data to confirm the conclusions of the Surge Line analysis.
This action will be completed prior to Unit 1 Fuel Load.
CPSES Unit 2 will be addressed prior to Hot Functional Testing for Unit 2.
Sincerely, ll*
William J. Cahill, Jr.
HAM /ddm Attachments j
Enclosures J
I c - Mr. R. D. Martin, Region IV w/o encl Resident Inspectors, (CPSES) (3) w/o encl i
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. to TXX-89228 May 1, 1989 Page 1 of 3 CHRONOLOGY OF CONSIDERATION OF PRESSURIZER SURGE LINE THERMAL STRATIFICATION DESIGN ANALYSIS AND LEAK-BEFORE-BREAK QUALIFICATION FOR COMANCHE PEAK UNIT 1 REF:
1)
TV Electric Letter from W. G. Counsil to NRC dated April 15, 1988 2)
TV Electric Letter from W. G. Counsil to NRC dated July 8, 1988 3)
NRC Letter from J. H. Wilson to TU Electric dated l
August 31, 1988 l
4)
TV Electric Letter from W. G. Counsil to NRC dated September 7, 1988 5)
NRC Letter from M. Malloy to TV Electric dated September 19, 1988 6)
TV Electric Letter from W. G. Counsil to NRC dated October 12, 1988 7)
TV Electric Letter from W. J. Cahill, Jr. to NRC dated February 21, 1989 8)
TV Electric Letter from W. J. Cahill, Jr. to NRC dated March 17, 1989 I
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On April 15, 1988, TU Electric submitted by reference (1) a leak-before-break i
report "CPSES-1 WHIPJET Program Report" which provided the necessary analysis and evaluation to support exclusion from the design basis of the dynamic effects of postulated ruptures of the 14 inch diameter Pressurizer Surge Line; I
the 12 inch diameter Residual Heat Removal Lines; and the 10 inch diameter i
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Accumulator Injection Lines.
As a result of the NRC review, a telephone
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conference call was held on June 22, 1988, among representatives of the NRC l
I staff, TV Electric, and Robert L. Cloud Associates (RLCA), Inc. to discuss the results presented in the CPSES-1 WHIPJET Program Report.
The NRC staff representatives requested that TV Electric perform six action items to enable the NRC to complete its review.
TV Electric completed the actions requested by the NRC by submittal of additional information by reference (2).
Shortly thereafter, the issue of whether the pressurizer surge line ought to l
be considered as a candidate for application of leak-before-break methodology
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was called into question by the "9C in light of operational events at the Trojan nuclear plant concerning unanalyzed thermal stratification in that line.
The NRC also stated that TV Electric would have to utilize actual end of life toughness values to qualify the Accumulator Injection Lines cast stainless steel nozzles for leak-before-break acceptability.
I L _ _____
. to TXX-89228 May.1, 1989 page 2 of 3 A public meeting on August 19, 1988 was held at the NRC office among representatives of the NRC, TV Electric, Westinghouse and RLCA to discuss TV Electric's proposed plans for demonstrating the acceptability of applying leak-before-break methodology to the pressurizer surge line of Unit 1 (meeting minutes and slides per reference (3)).
A follow-up public meeting was held on September 7, 1988 at the NRC office to discuss NRC feedback, presentation of industry initiatives and specific details of TV Electric's proposed plan to resolve this issue (meeting minutes and slides per references (4) and (5)).
The NRC, on December 20, 1988, issued "NRC Bulletin 88-11: Pressurizer Surge Line Thermal Stratification" that requires all holder's of OL's or (P's for Pressurized Water Reactors to establish and implement a program to ccafirm pressurizer surge line integrity in view of the occurrence of thermal stratification.
On February 21, 1989 a public meeting at the NRC office was held among representatives of the NRC, TV Electric and Westinghouse to discuss the results of:
- Thermal stratification analysis and leak-before-break qualification for the Comanche Peak Unit 1 Pressurizer Surge Line.
- Additional analysis performed to support conclusions that stratification does not occur in the 12 inch diameter RHR suction lines due to adequate fluid mixing.
This additional analysis was performed in response to an NRC request that an event that had occurred at a foreign reactor be evaluated and incorporated into the RHR leak-before-break qualification for Comanche Peak Unit 1.
4 In a telephone conversation on March 1,1989, between M. Fields (NRR), and H. A. Marvray (TV Electric) it was agreed that TV Electric would provide the NRC by May 1, 1989, a report containing the analysis of Surge Line stratification and leak-before-break qualification.
The report would also provide an additional analysis to address issues concerning RHR suction line stratification discovered at a foreign reactor.
The Surge Line thermal stratification analysis and leak-before-break reports (proprietary and non-proprietary versions) are provided as enclosure one and two respectively.
During the final processing and assembly of the reports, the following incorrect statement was inadvertently included on page 3-2 and should be removed:
"The pressurizer nozzle load was also specially qualified by finite I
element analysis technique."
l The NRC ultimately issued "NRC Bulletin No. 88-08 supplenn Thermal Stress In Piping Connected to Reactor Coolant Systems" wl m provided information pertaining to RHR suction line stratification :
c the NRC had
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i i to TXX-89228 May 1, 1989 j
Page 3 of 3 j
i previously requested TV Electric address before RHR leak-before-break i
qualification could be considered acceptable.
On April 21, 1989, via telephone call with M. Fields (NRR), TV Electric requested and received an extension to May 9, 1989 for the submittal of the analysis and leak-before-break qualification for the two (2) 12 inch diameter RilR suction lines.
The j
remaining actions will be provided as previously discussed above.
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. to TXX-89228 May 1, 1989 Page 1 of 1 1
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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Texas Utilities Electric Company
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Docket Nos. 50-445
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50-446
-1 (Comanche Peak Steam Electric
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Station, linits 1 & 2)
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AFFIDAVIT W. J. Cahill, Jr. being duly sworn, hereby deposes and says that he is Executive Vice President, Nuclear of TV Electric, the Applicant herein; that he is duly authorized to sign and file with the Nuclear Regulatory Commission this response to NRC Bulletin 88-11; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief.
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W. V Cahill, Jr.# 7 Executive Vice President, Nuclear l
STATE OF TEXAS
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COUNTY OF DALLAS
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Sugcribedandsworntobeforeme,aNotary u
n and for w
, on this dR% day of 1989.
u-I CAROLYN 4.WILLIAleS 88888 1
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dd D My commission ex es:
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