ML20245J886
| ML20245J886 | |
| Person / Time | |
|---|---|
| Site: | 05000601 |
| Issue date: | 06/28/1989 |
| From: | Wiesemann R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | Chris Miller Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19312B312 | List: |
| References | |
| AW-89-086, AW-89-86, NUDOCS 8907030206 | |
| Download: ML20245J886 (38) | |
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Westinghouse Energy Systems Ba 355 Pmsburgh Pennsylvania 15230-0355 Electric Corporailon June 28,1989 AW-89-086 Docket No. STN-50-601 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Charles L. Miller, Director Standardization & Non-Power Reactor Project Directorate APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
Westinghouse Response to Draft Safety Evaluation Report (DSER)
Open Issues 1-41 in Review of RESAR-SP/90 PDA
Reference:
Letter No. NS-NRC-89-3446, Johnson (W) to Miller (NRC) dated June 28, 1989
Dear Mr. Miller:
The application for withholding is submitted by Westinghouse Electric Corporation (" Westinghouse") pursuant to the provisione of paragraph-(b)(1) of Section 2.790 of the Commission's regulations. It coni.ains commercial strategic information proprietary to Westinghouse and customarily held in i confidence. l The affidavit previously provided to justify withholding proprietary information in this matter w; submitted as AW-82-57 with letter NS-NRC-85-3001, dated January 31, 1985 and is equally applicable to this material.
Accordingly, it is respectfully requested that the subject information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10CFR Section 2.790 of the Commission's regulations.
Correspondence with respect to this application for withholding or the accompanying affidavit should reference AW-89-086 and should be addressed to the undersigned.
Ve, truly yours, g&kHGZu1 WMS/ jag /0453B Robert . Wiesemann, Manager Enclosure (s) Regulatory & Legislative Affairs ,
cc: E. C. Shomaker, Esq.
Office of the General Counsel, NRC 8907030206 890628 [M PDR ADOCK 05000601 -
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l-PROPRIETARY INFORMATION NOTICE j 1
TRANSMITTED HEREWITH ARE PROPRIETARY AND/0R NON-PROPRIETARY VERSIONS OF DOCUMENTS FURNISHED TO THE NRC IN CONNECTION WITH REQUESTS FOR GENERIC AND/0R PLANT SPECIFIC REVIEW AND APPROVAL. J l
IN ORDER TO CONFORM TO THE REQUIREMENTS OF 100FR 2.790 0F THE COMMISSION'S REGULATIONS CONCERNING THE PROTECTION OF PROPRIETARY INFORMATION SO SUBMITTED 1 TO THE NRC, THE INFORMATION WHICH IS PP.0PRIETARY IN THE PROPRIE1ARY VERSIONS IS j CONTAINED WITHIN BRACKETS AND WHERE THE PROPRIETARY INf0RMATION HAS BEEN j DELETED IN THE NON-PROPRIETARY VERSIONS ONLY THE BRACKETS REMAIN, THE l INFORMATION THAT WAS CONTAINED WITHIN THE BRACKETS IN THE PROPRIETARY VERSIONS HAVING BEEN DELETED. THE JUSTIFICATION FOR CLAIMING THE INFORMATION S0
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DESIGNATED AS PROPRIETARY IS INDICATED IN BOTH VERSIONS BY MEANS OF LOWER CASE l l LETTERS (a) THROUGH (g) CONTAINED WITHIN PARENTHESES LOCATED AS A SUPERSCRIPT l IMMEDIATELY FOLLOWING THE BRACKETS ENCLOSING EACH ITEM 0F INFORMATION BEING I IDENTIFIED AS PROPRIETARY OR IN THE MARGIN OPPOSITE SUCH INFORMATION. THESE !
LOWER CASE LETTERS REFER TO THE TYPES OF INFORMATION WESTINGHOUSE CUSTOMARILY HOLDS IN CONFIDENCE IDENTIFIED IN SECTIONS (4)(ii)(a)~THROUGH (4)(ii)(g) 0F THE AFFIDAVITACCOMPANYINGTHISTRANSMITTALPURSUANTTO10CFR2.790(b)(I).
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AW-88-122- I i
AFFIDAVIT l l
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COMMONWEALTH OF PENNSYLVANIA: .
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COUNTY OF ALLEGHENY:
i Before me, the undersigned authority, personally appeared Robert A. Wiesemann, who,- being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Corporation (" Westinghouse") and thrt the averments of fact-set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:
7J if Yi] k HV1 H U '
Robert A. Wiesemann, Manager Regulatory and Legislative Aff'.ir.;
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Sworn to and subscribed before me this ~74 day of M gg1988. l l
i Notary Public l NOTARitt sEFL LORRAINE M. PIPLICA, NOTARY FU3Lt0 i MoNROEV!LLE BORO. ALLE3 4E.WOCUNTY l
MYCoMM:CSiON EXPIRES CE: 14.19?1 '
Member, Psnnsylvane Assecat:n of fWmms
j AW-88-122 (1) I am Manager, Regulatory and Legislative Affairs, in the Nuclear and Advanced Technology Division, of the Westinghouse Electric Corporation :nd as such, I have been specifically delegated the function of reviewing the proprietary information sought to be !
withheld from public disclosure in connection with nuclear power ,
plant licensing and rulemaking proceedings, and am authorized to l apply for its withholding on behalf of the Westinghouse Energy Systems, Nuclear Fuel, and Power Generation Business Units. !
(2) I am making this Affidavit in conformance with the provisions of 10CFR Section 2.790 of the Commission's regulations and in conjunction with the Westinghouse application for withholding accompanying this Affidavit.
(3) I have personal knowledge of the criteria and procedures utilized by the Westinghouse Energy Systems, Nuclear Fuel, and Power Generation Business Units in designating information as a trade secret, privileged or as confidential commercial or financial'information. i (4) Pursuant to the provisions of paragraph (b)(4) of Section 2.790 of
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the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld, i
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(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse. l 1
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AW-88-122 i i
(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. 4 Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The
. application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis-required.
l Under that system, information is held in confidence if it falls l in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows: '
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(a) The information reveals the distinguishing aspects of a l process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors l
without license from Westinghouse constitutes a competitive i economic advantage over other companies. I (b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a 4 competitive economic advantage, e.g., by optimization or improved marketability.
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I (c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.
(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.
(e) It reveals aspects of past, present, or future. Westinghouse j or customer funded development plans and progrcms of potential. commercial value to Westinghouse..
l (f) It contains patentable ideas, for which patent protection may be desirable.
(g) It is not the property of Westinghouse, but must be treated as proprietary by Westinghouse according to agreements with j the owner. l There are sound policy reasons behind the Westinghouse system which include the following:
(a) The use of such information by Westinghouse gives '
Westinghouse a competitive advantage over its competitors.
It is, therefore, withheld from disclosure to protect the l Westinghouse competitive position.
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AW-88-122 'i (b) It is information which is marketable in many ways. .The -
extent to which _such information is-available to . l competitors diminishes the' Westinghouse ability to sell ;!
products and services involving'the .use' of the information.
1 (c) Use by our competitor-would put. Westinghouse at a competitive disadvantage by. reducing his expenditure of resources at our expense.
(d) Each component of: proprietary information pertinent to a .,
particular. competitive advantage is potentially as'valuableL ~i as the total competitive advantage. . If competitors acquire components of proprietary information, any one component. i may be the key to the entire puzzle,-thereby depriving-Westinghouse of a competitive advantage.
i (e) Unrestricted disclosure would jeopardize the position of j prominence of Westinghouse in the world market, and thereby' give a market advantage to the competition of those countries.
(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in ,
obtaining and maintaining a competitive advantage.
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AW-88-122 i
(v) The proprietary information sought'to be withheld in this su'bmittal is that which is appropriately marked in the
' Westinghouse Advanced Pressurized Water Reactor (MAPWR) ,
Licensing Control Document", Amendment 4 to MAPWR RESAR-SP/90 PDA Module 5, " Reactor System", being transmitted by i Westinghouse, W. J. Johnson, Manager Nuclear Safety Department to NRC, C. L. Miller, Director, Standardization and Non-Power Reactor Project Directorate, NS-NRC-88-3382, November 8, 1988. .
This document identifies specific design features and l
l improvements which the WAPWR will have in order to meet current regulatory requirements. In addition, it establishes the EAPWR j l position with respect to each applicable requirement. '{
Public disclosure of this information is likely to cause 1
substantial harm to the competitive position of Westinghouse as '
it would reveal the description of the improved design features of the MAPWR; Westinghouse plans for future design, testing and analysis aimed at design verification; and demonstration of the design's capability to meet evolving NRC/ACRS safety goals. All of this information is of competitive value because of the large amount of effort and money expended by Westinghouse over a l
period of several years in carrying out this particular development program. Further, it would enable competitors to use the information for commercial purposes and also to meet NRC requirements for licensing documentation, each without purchasing the right from Westinghouse to use the information.
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1 AW-88-122 i
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Information regarding its development programs is valuable to Westinghouse because:
(a) Information resulting from its development programs gives ]
Westinghouse a competitive advantage over its competitors. I It is, therefore, withheld from disclosure to protect the '
Westinghouse competitive position.
(b) It is information which.is marketable in many ways. The extent to which such information is available to j competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.
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(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.
(d) Each component of proprietary information pertinent to a particular competitor advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle thereby depriving Westinghouse of a competitive advantage.
(e) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.
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1 AW-88-122 l Being an innovative concept, this information might not be discovered by the competitors of Westinghouse independently. To 3 duplicate this information, competitors would first have to be l similarly inspired and would then have to expend an effort similar to that of Westinghouse to develop the design.
1 Further the deponent sayeth not. I I
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.. . q -o WESTINGHOUSE CLASS ~3 RESAR-SP/90 PDA Response' to Draft Safety. Evaluation.
Report Open Issues 01-41.
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WEC P.O. Box 355 Pittsburgh, PA- 15230 MAPWR-DSER JUNE 1989 i
DSER Open Issue 1: Interface criteria for structur'ai design features (3.1).
Response
As stated in Subsection 1.1.1.1 of RESAR-SP/90 PDA Module 3, " Introduction and Site," the RESAR-SP/90 PDA design includes additional design scope beyond the traditional Westinghouse NSSS, designated as the Nuclear Power Block (NPB), to include all Seismic Category I structures, systems and components that are essential to the safe and proper operation of the nuclear power plant. The
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balance of' plant (B0P) includes the turbine building, the waste disposal !
building, the service and administration buildings, and the essential service- )
water / cooling water structure end the ultimate heat sink. Table 1.1-1 of l RESAR-SP/90 PDA Module 3 provides the list of NPB components (including.
structures and systems), and those non-NPB components which require that design and interface criteria be provided.
I Subsection 1.9.1 of RESAR-SP/90 PDA Module 3 identifies'the safety related 1 interfaces between the NPB and the site specific items which will be addressed !
by the plant specific applicants referencing the RESAR-SP/90. Table 1.9-3 provides a listing of site parameters, the magnitude specified in the design of the NPB and the module where the interface requirement is further discussed.
1 Westinghouse believes that the structural design interface requirements are provided in that table and throughout the structural design description sections.
DSER Open Issue 2: Review of flow diagrams showing quality group classification (3.2.1). ;
Response
The resolution of this issue is contingent upon the completion of the staff's review of RESAR-SP/90 flow diagrams and Westinghouse's resolution of Open Issue 3. This open issue will therefore be addressed in the final SER.
WAPWR-DSER 1 JUNE 1989 E978e:1d i
t DSER Open Issue 3: Quality group classification of strectures, systems and components (3.2.1, 3.2.2). 1 i
Response
Per several conference call discussions with staff. mambers (Engineering Branch), it was agreed that it was acceptable for Westinghouse to use ANSI /ANS 51.1-1983 in - its safety classification for pressure retaining systems and components. However, ANSI /ANS 51.1 will not be used for classifying non pressure-retaining components, and SP/90 must me e t the requirements of 10CFR50, Appendix B and Regulatory Guide 1.26.
Additionally, it was agreed that previously unacceptable responses (as stated on pages 3-3 and 3-4 of the March 1988 DSER) to NRC questions 210.1, 210.3, 210.12, 210.13, 210.16, 210.25, 210.27, 210.29, 210.34, 210.35 and 210.72 l would now be acceptable to staff.
l Our review of the initial responses to staff questions 210.6 through 210.9 indicates they are essentially correct but require some clarification as shown below:
Q/A 210.6: Accurate as written, j
4 Q/A 210.7: A clarification is in order: The pressure boundary of the ]
shell side of the letdown and excess letdown heat exchangers- 1 is not required for any safety class functions, while the pressure boundary of the tube side is specified as Safety Class 3. The tubes are Safety Class 3 in order to ensure their integrity, because they normally contain radioactive j fluid. .
1 l l Therefore, while the pressure boundary of the .shell side of these heat exchangers has no special safety classification, it j l is required to mechanically support the tube bundles. I l
l WAPWR-DSER 2 JUNE 1989 l B978e:Id i
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0/A 210.8 The SP/90 design does not incorporate a seal water heat exchanger to cool the flow returning from the reactor coolant pump seals; instead it incorporates a seal injection heat exchanger to cool the water flowing into the seals. The -l return flow will be within the operating temperature range of the CVCS volume control tank. 1 I
Thus, Table 3.2-1 correctly lists a seal injection heat exchanger (new as part of the SP/90) and not a seal return ;
heat exchanger (traditional).
0/A 210.9 Accurate as written.
A discussion of the endurance of the Westinghouse Model 100A pump / seal experiencing full temperature operation, with a loss of seal injection has j been provided. The discussion includes examples of testing and analysis of {
this model pump.
1 Westinghouse RC pumps have used a system of . combined CCW cooled thermal barriers and cool seal injection since the inception of shaft seal pumps for l PWR service in Westinghouse design plants. In addition to the Model 100A, there are Models 63, 70, 93, 93A, 93D and 93A-1 thermal barrier designs. ]
A methodology for design by analysis has been developed and used in the design of over 300 pumps manufactured by Westinghouse and its licensees. Customer I events involving loss of injection are not well documented, however, evidence I of field investigations indicate that many events have been experienced with no adverse or even significant consequences. In addition to the design i calculations prepared for the detailed pump design, . full scale performance tests have been conducted on the Model 100 RC pump and thermal barrier '
models. Overall a total of [ ] Model 100 RC pumps have been manufactured' and b,c received full pressure and temperature tests at WEMD Cheswick. As a minimum, a [ ] hour loss of injection test was conducted on each pump (some additional b,c :
testing was performed on the lead unit Krsko #1 and on Vandellos 2 pump S/W 2). In all cases, the pump / seal combinations achieved stable operation !
within the normal recommended limits of pump seal operation.
WAPWR-DSER 3 JUNE 1989 E978e:Id i
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1 The RCP thermal barrier adequacy depends on two factors, the ultimate heat extraction capability of the pump cooling coils and thermal barrier, end the thermal coefficient of the No. I seal. Briefly the thermal barrier must have ,
the heat capacity to deliver water to the seal inlet at a low enough temperature and in sufficient quantity to assure that the seal achieves a stable operating condition. {
t Since viscosity decreases with increasing temperature, conver.ging tapered hydrostatically balance No. I seals of the type used exclusively in !
Westinghouse pumps, exhibit increasing leakage rate with increasing seal inlet-temperature. In addition to the effect of viscosity there are thermal /
mechanical effects on the seal components which can result in increasing leakage with increasing temperature. All of the Model 100 pungs were tested l
with Aluminum 0xide style No. I seals. All Model 100 pumps achieved a stable I thermal and leakage equilibrium with the injection off. Typical pump response to the loss of injection is shown in the attached curve plotted from the
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Vandellos 2 pump data. Experience with the present Silicon Nitride No. I seal j design indicates that this design has approximately half of the change in leakage /*F that was exhibited by the original Aluminum Oxide design. With respect to the silicon nitride seal design (currently supplied with all new pumps) the Model 100 has more heat removal margin than it did relative to the original aluminum oxide seal design.
The Model 100 RCP has substantial endurance (weeks or months) with the seal injection off. Ultimately the operating time in this mode is only limited by recommended inspection frequencies and seal life. The WEMD instruction book, however, recommends limiting operation in this mode to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This recommendation is based on limiting the opportunity for the combined loss of i injection and loss of CCW event (loss of all seal cooling). j i
Figure 01-3 shows the injection flow rate (mostly zero), seal inlet i temperature and seal leakage during the >4 hour loss of injection test for Vandellos S/N-2, U431. The seal inlet can be seen to stabilize at about 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> into the test, and likewise the No. I seal leakage rate can be seen to come to an equilibrium condition.
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WAPWR-DSER 4 JUNE 1989 E97Be:Id j
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a Not shown is the injection temperature which was [ ] at the start of this b,c l test, and which is restored at [ ). This is~a thermal shock test for b,c )
seal integrity. It can be seen that the seal responds initially with a sharp reduction in leakcge rate and then begins to recover toward the normal equilibrium leakage rate. This test was considered to be both typical, and i highly successful.
DSER Open Issue 4: Safety classification of safety-related instrument lines (3.2.2). I
Response
This topic is currently being reviewed by the Staff as part of ongoing activities related to the EPRI ALWR Requirements Document, Chapter 6. At this time, Westinghouse adopts the Industry position, which can be summarized as follows:
" Safety related instrument sensing lines will be designed in'accordance '
with ASME III except for supports which will be Seismic Category I, but will not be designed to ASME NF criteria. Installation will be in accordance with a OA Category I, non-ASME program that meets '10CFR50 Appendix B requirements." !
i If the industry position were to change in the future in order to achiave resolution of staff concerns, Westinghouse agrees to adopt such retised position in its FDA application.
DSER Open Issue 5: Quality group classification of reactor internals (3.,2.2, 3.9.5). l Response: ,
The reactor internals are classified Safety Class 3 in accordance with ANSI /ANS 51.2. However, it should be noted that. contrary to the Staff's understanding as expressed in the Narch 1988 DSER, the reactor internals are WAPWR-DSER 6 JUNE 1989 5978e:1d
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not ASME Class 2 since reactor internals are designed in accordance with the '
requirements of Subsection NG of ASME III as indicated in Table 3.2-1 of RESAR SP/90 Module 7
- Structural / Equipment Design." Since. additionally the same table designates the reactor internals as belonging to Quality Group B, it is 1 Westinghouse's opinion that the Staff's concerns are adequately addressed and that, in fact, the Safety Classification has little or no practical significance in the particular case of the reactor internals. !
l DSER Open Issue 6: Tornado loadings--maximum wind speed (3.3.2).
Response
Westinghouse has reviewed the NRC staff's interim position on _ design basis tornado characteristics and agrees to utilize this interim position in lieu of the recommendations of ANSI Standard 2.3, 1983.
The maximum tornado wind speed of 330 mph will be utilized in establishing the velocities of the postulated tornado missiles. The plant will be designed for the Spectrum 11 missiles identified in Standard Review Plan 3.5.1.4, Rev 2.
The missile velocities corresponding to the design maximum wind speed of 330 mph will be taken as the average of the velocities given for Region I (maximum wind speed = 360 mph) and Region II (maximum wind speed = 300 mph). i i
Subsections 3.3.2 and 3.5.1.4 of RESAR-SP/90 PDA Module 7 " Structural /
Equipment Design" have been revised to show the above positions.
DSER Open Issue 7: Internally generated missiles outside containment :
(3.5.1.1).
Response
This open issue involves a continuing review on the part of the staff, and Westinghouse will take no action unless the results of this review are issued prior to the Final SER.
WAPWR-DSER 7 JUNE 1989 5978e:1d
DSER Open Issue 8: Internally generated missiles inside containment (3.5.1.2).
Response
This open issue involves a continuing review on the part of the staff, and Westinghouse will take no action unless the results of this review are issued prior to the Final SER.
DSER Open issue 9: Local and overall damage predictions (3.5.3).
Response
See the Westinghouse response to Open Issue 11.
DSER Open Issue 10: Maximum concrete thickness for barrier design (3.5.3).
Response
See the Westinghouse response to Open Issue 11.
DSER Open Issue 11: Ductility ratio (3.5.3),
Response
Westinghouse has committed to comply with the NRC position on local and overall damage predictions as stated i_n SRP Section 3.5.3, paragraphs 11.1 and 2. Most of these commitments are already incorporated in RESAR-SP/90.
Criteria for local damage prediction are given by the empirical equations for perforation and scabbing of concrete and steel barriers in Subsection 3.5.3 of RESAR-SP/90 PDA Modulo 7, " Structural / Equipment Design." Minimum thicknesses l of external barriers designed to resist tornado missiles are given in Subsection 3.5.1.4 of RESAR-SP/9D PDA Module 7. Criteria for overall damage prediction are also given in Subsection 3.5.3 of Nodule 7 which references applicable codes or specifications for the stress and strain limits. Concrete WAPWR-DSER 8 L e' 1989 5978e:Id
J structures are designed to ACI-349 (see Subsections 3.8.3.2 and 3.8.4.2 of RESAR-SP/90 PDA Module 7) which defines maximum allowable ductility ratios for ]
missile impact. Westinghouse will comply with the additional NRC ;:ositions on I ductility of concrete structures contained in Regulatory Guide 1.142 which l r'dorses ACI-349. Steel structures are designed to AISC (See Subsections ]
3.8.3.2 and 3.8.4.2). Maximum allowable ductility ratios for steel structures
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have been added in Subsection 3.5.3 of Module 7.
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.i DSER Open Issue 12: Postulated breaks in American Society of Mechanical
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Engineers (ASME) Class 1 piping (3.6.2).
Response
There are no changes to RESAR-SP/90. The recent change in the NRC SRP >
j (June,1987) concerning the use of Equation (10) alone for determining pipe l rupture locations was intended to simplify ihe engineering caNulations without resulting in more pipe rupture locations than the earlier version of the SRP (July, 1981). This conclusion was predicated on the removal from j Equation (10) of the linear thermal gradient stress term, and the projected successful application of leak-Lefore-break (LBB) to all Class 1 piping. In practice, because of leak detection capabilities, only larger piping (six inches and larger) will qualify for LBB. For smaller piping in Westinghouse PWR's, this change will lead to more pipe rupture locations which could adversely affect safety by increasing plant congestion and maintenance activities. The NRC staff is requested to evaluate the total impact of this SRP change before requiring implementation by the industry.
In addition, the recent SRP limit on Equation (10) for Class 1 piping is 80%
of 3.0 Sm. This is not equivalent to the 80% SRP requirement on Equations (9) and (10) for Class 2 and Class 3 piping. For Class 1 piping, the ASME Code provides limits for Equations (12) and (13), as well as cumulative usage factor requirements; the Code has no limit for Equation (10). For Class 2/3 piping the ASME Code does provide limits on Equations (9) and (10). The use of Equations (12) and (13) provides a more appropriate basis for postulation WAPWR-DSER 9 JUNE 1989 E978e:1d
of breaks in Class 1 piping, and is consistent with the criteria used for Class 2/3 piping._ Further, the use of Equation (10) alone .aakes the stress criteria in break exclusion zones less restrictive than for other Class 1 piping. The current requirement to postulate pipe rupture in Class 1 piping baced on Equation (10) alone is unjustified and could have an overall adverse impact on plant .dy .
DSER Open Issue 13. Classification of non-ASME Class piping (3.6.2).
Response
There are no changes to RESAR-SP/90. The design basis for non-seismic piping in the vicinity of seismic piping is discussed in Subsection 3.7.3.13 of RESAR-SP/90 PDA Module 7, " Structural / Equipment Design." The non-seismic piping is analyzed for the SSE condition. Seismically analyzed non seismic piping need not be reclassified as Seismic Category I piping.
DSER Open Issue 14: Compliance with Branch Technical Position (BTP) HEB 3-1 (3.6.2).
Response
The following has been inserted before the last ,centence on Page 3.6-11 of Subsection 3.6.2.1.1E in RESAR-SP/90 PDA Module 7, " Structural / Equipment Design":
A structure that separates a high-energy line outside containment, which has not been demonstrated to meet mechanistic pipe break requirements, from an essential component is designed to withstand the consequences of the pipe break in the high-energy line which produces the greatest effect at the structure, irrespective of the fact thst the criteria of Section 3.6.2.1.1B & C might not iaquire such a break to be postulated.
WAPWR-DSER 10 JUNE 1989 5978e:Id
DSER Open Issue 15: Pressure test of guard pipe (3.6.2).
Response
Subsection 3.6.2.4 of RESAR-SP/90 PDA Module 7, " Structural / Equipment Design,"
has been revised as follows to reflect the staff position:
" Guard pipe assemblies are designed in accordance with ANSI /ANS 58.2-1988 except that the pressure test is performed at a pressure not less than their design pressure. The design pressure is the maximum operating pressure of the enclosed process pipe."
DSER Open Issue 16: Limits of break exclusion area for ASME Class 2 piping (3.6.2).
Response
There are no changes to RESAR-SP/90. The purpose of the restraints is to assure that the isolation valves can close if a pipe rupture were to occur outside containment beyond the restraint. Westinghouse has located the restraint as close as pmeticable to the valve. If a pipe rupture is postulated between the isolation valve and the restraint, valve operability l could not be assured. This position is consistent with current industry practice, which has been accepted by the NRC on existing nuclear plants.
Strict compliance with the position, as stated in MEB 3-1, is not practical. 4 DSER Open Issue 17- Dynamic load factor for pipe whip restraints (3.6.2).
Response
I The response to NRC Question 210.46, submitted in Amendment 2. to RESAR-SP/90 l PDA Module 7, " Structural / Equipment Design," has been revised regarding the dynamic load factor. Also see the reply to DSER Open Issue 18.
I WAPWR-DSER 11 JUNE 1989 5978e:1d j
i DSER Open Issue 18: Design of pipe rupture r.itraints (3.6.2). '
Response
The response to Question 210.46 has been revised to reflect the staff's position.
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"Where supports are attached to restraint structures the restraint is
)
designed to the criteria described in Subsection 3.9.3.4 of RESAR-SP/90 I PDA Module'7, " Structural / Equipment Design," for ASME Code,Section III j supports. l The design of pipe whip restraint structures includes a dynamic load factor. This factor accounts for the inertia load in the restraint structure and its value depends on the dynamic characteristics of the structural system."
i DSER Open Issue 19: Synthesized time histories (3.7.1).
Response
The information requested by the staff in their letter dated September 22, l 1987 was incorporated in Amendment 2 (January 1989) to RESAR-SP/90 PDA l Module 7, " Structural / Equipment Design" in the response to Staff Question 220.3. J l
DSER Open Issue 20: Soil damping model (3.7.1, 3.7.2).
Response: I Subsection 3.7.2.15 of RESAR-SP/90 PDA Module 7, " Structural / Equipment )
Design," was revised in Amendment 2 (January 1989) to correct the description of damping used for the soil medium. As described therein, the analysis I utilized frequency independent soil springs and dampers. The magnitudes for 4
WAPWR-DSER 12 JUNE 1989 5978e:1d I
these springs and dampers were based on the standard equations enumerated in Tables 3300-1 and 3300-2 of ASCE Standard 4-86.
DSER Open Issue 21: Inservice inspection program for seismic instrumentation (3.7.3).
Response
Surveillance requirements for the seismic monitoring instrumentation described-in Subsection 3.7.4 of RESAR-SP/90 PDA Module 7, " Structural / Equipment Design" will be provided in the Standard Technical Specifications to be supplied at the final design stage. Each of the seismic instrumentation will require demonstration of operability by the performance of the channel check, channel calibration and an analog channel operational test. The measurement range and minimum number of instruments required to be operable will be established to meet.the recommendations of Regulatory Guide 1.12.
DSER Open Issue 22: Containment design criteria (3.8.1).
Response
Westinghouse has identified criteria for the design of the containment in Subsection 3.8.1 of RESAR-SP/90 PDA Module 7, " Structural / Equipment Design,"
and amplified by the response to NRC Question 220.8 submitted in Amendment 2 to Module 7. Westinghouse considers the criteria to be adequate and applicable to the design of the ::pherical containment vessel which is generally unstiffened, as well as to those local regions of the vessel whe"e stiffeners are used such as for the crane girder and its supports. These criteria will be incorporated in the Design Specification which provides the design requirements to the containment vessel supplier.
1 1
l WAPWR-DSER 13 JUNE 1989 5978e:Id
l DSER Open Issue 23: Limited design audit of containment design (3.8.1).
Response
Containment design has been performed sufficiently .to establish the overall dimensions and general plate thickness. These overall parameters will be incorporated in the ASME Design . Specification together with the design )
criteria documented in RESAR-SP/90 and all design loadings. As identified.in l RESAR-SP/90, it is the applicant's intention that the. containment vessel be-constructed in accordance with ASME requirements. Thus, the design as well as the construction will be performed'by a containment vessel ~ supplier. The NRC staff's limited design audit should occur after the vessel designer has been selected and design calculations.have been prepared. 1
.l DSER Open :ssue 24: Description of FATCON and WESAN computer programs (3.9.1). l l
Response
The following descriptions of computer codes FATCON and WESAN have been added )
to Section 3.9 of RESAR-SP/90 PDA Module 7, " Structural /Equipnent Design," as Appendix 3.9.
)
f i
{
WAPWR-DSER 14 JUNE 1989 5978e:1d
APPENDIX 3.9 COMPUTER CODE FATCON.
. Introduction Program FATCON is used to perform fatigue analysis in accordance with the ASME 1
S9ction III Code, Subsection NB-3600. For all possible ? cad-set combinations, '
ATCON calculates the following:
- 1. Primary plus-secondary stress. intensity range
- 2. Peak stress intensity range
~3. Elastic plastic penalty factor
- 4. Incremental cumulative usage factor-The total cumulative usage factor at a point is the summation over all load-set combinations of the incremental cumulative usage factor. The program also f provides stress range information for use in satisfying the ASME Section III l rules for simplified elastic plastic discontinuity analysis. The stress range !
I !
) a,c.e j 1
Primary-Plus-Secondary Stress Intensity Range .i
. This. stress intensity range consists of the sum of pressure, moment, and axial )
temperature discontinuity stresses. The pressure stress is determined from l a,c.e.
[ ] This stress index ;
is based on the ASME Sectio:1 III, 1986 Code.
The moment stress' is_ [ <
a,c.e 1
)
WAPWR-DSER 15 JUNE 1989 5978e:1d
a,c.e 1
l l
l Peak Stress Intensity Range 4
Moment and axial temperature discontinuity stresses are determined in a
--similar manner as shown in previous section. [ {
a,c.e
) ,
Elastic-Plastic Penalty Factor i l
The elastic plastic penalty factor is determined from the primary plus- J secondary stress intensity range and [ j
). The program provides the ASME Section III, Subsection NS-3228, values of material parameters "m" and "n".
Incremental Cumulative Usace Factor j The incremental cumulative usage factor is determined from the elastic plastic j j penalty factor and peak stress intensity range described above. The program j provides the ASME Section III, Appendix I, Figure I-9.2 values of alternating
. stress versus number of cycles. ,
l, COMPUTER CODE WESAN i
The WESAN computer program was developed by Westinghouse to accomplish RCL equipment support structure analyses and code evaluation. The evaluation is WAPWR-DSER 16 JUNE 1989 5978e:1d l
l
performed for. the Normal, ' Upset, Emergency, and . Faulted plant operating conditions; the Faulted evaluation is completed on a time-history basis.
a,c.e i
1 l
Forces on the structure are combined, by absolute sum or by.
square-root-sum of-the-squares, [
a,c.e
]
All input data are included in the printed output along with a table of maximum member forces and interaction ratios.
(
WAPWR-DSER 17 JUNE 1989 E978e:Id
DSER Open Issue 25: Analysis standard for time-history solutions and response spectrum analysis (3.9.2.2).
Response
The use of ASCE seismic analysis standard, " Seismic Analysis of Safety-Related Nuclear Structures," in time-history solutions and response spectrum analysis of SP/90- subsystems was discussed during several telecons between Westinghouse and staff members from the Engineering Branch. It was decided that staff (ESGB and EMEB) would further review this standard to determine a. final (acceptable / unacceptable) position on its application in the SP/90 design.
. Westinghouse will defer their response until this final position has been established.
DSER Open Issue 26: Combination of closely spaced modes in seismic . response analysis-(3.9.2.2).
Response
Subsection 3.7.3.7 of RESAR-SP/90 PDA Module 7, "Stri-tural/ Equipment Design,"
and response to Question 210.50 have been revised to clarify the Westinghouse position. This position meets the intent of Regulatory Guide 1.92.
- 1. The first paragraph of Subsection 3.7.3.7 (page 3.7-15) has been modified f'
to read as follows:
"The total co-directional seismic response is obtained _by combining :
the individual modal responses utilizing the SRSS method. For sy tems l having modes with closely spaced frequencies, this method is modified l to include the possible effect of these modes."
l WAPWR-DSER 18 JUNE 1989 E978e:1d
q --
i
~
- 2. Revise the definition of R $
in Equation (2) of Subsection- 3.7.3.7 (page 3.7-16) as follows:
I "R$ = absolute value of the response of mode i."
- 3. The Response to Question 210.50.has been revised as follows:
i j
Delete the existing response in its entirety' and insert the following ,)
paragraph:
The methodology for combination of modes- with closely. spaced. !
frequencies in Subsection 3.7.3.7 of RESAR-SP/90 PDA Module 7 has been q revised to utilize the absolute value of the modal responses.
]
I DSER Open Issue 27: High-frequency modes in seismic response analysis f
(3.9.2.2). -l 1
Response: l There are no changes to RESAR-SP/90. Westinghouse believes chat the options to account for high frequency (> 33 Hz) modes in Subsection. 3.7.3.7 of RESAR-SP/90 PDA Modulo 7, " Structural / Equipment Design," are acceptable alternatives to the requirements in SRP Section 3.7.2 as explained below. The s SRP requirement to assure that inclusion of additional modes does not increase the response by more than 10% was intended to assure that no significant high )
frequency modes were omitted from the solution. This requirement is important only when the high frequency modes are being omitted. However, the high frequency modes are included in all of the options in Subsection 3.7.3.7 of Module 7.
When any of the above options are used, the key parameter becomes the upper bound frequency that is chosen for the flexible modes. The value of 33 Hz is appropriate when the amplitude of the design floor response spectra is closely WAPWR-OSER 19 JUNE 1989 i E978e:1d
)
1
- _ - __ - _ _ _ _ _ _ _ - _ _ _ - - _ . _ - - - _ _ _ - - _ - _ _ _ - - - - - - _ . I
approaching the zero period acceleration value of the floor at a frequency 'of -
33 Hz. This is valid for b'uildings in nuclear power plants which' typically have fundamental frequencies of less than 20 Hz.
DSER Open Issue 28: Representative maximum modal response in seismic response spectrum analysis (3.9.2.2).
. Response:
Subsection 3.7.3.9.A.2 of RESAR-SP/90 PDA Module 7, " Structural / Equipment Design," has been revi:;ed as shown below:
" Proportional Input -
For proportional input, the support motion at a' given point can be .
i obtained through multiplication of a reference excitation by a real number. This type of input is applicable in the case of support locations in the same supporting structure and is analogous to the use of the proper q phase characteristic of the building motion for the calculation of response due to seismic anchor motions (Subsection 3.7.3.9.B). For this type of input, the representative maximum modal response is obtained- by algebraic combination of contributions of the individual support point inputs. This combination is applicable when the response of the supporting structure is dominated by modes with in phase displacement,.
such as rigid body modes and low frequency modes. I Non proportional. Input -
For non proportional input, the support motions at each location :annot be obtained by multiplication of a reference excitation by a real number.
This type of input is applicable in the case of support locations in different supporting structures. The representative maximum modal responso is obtained by square root sum of the square combination of the l
contributions of the individual support point inputs (Reference 14).
l WAPWR-DSER 20 JUNE 1989 3978e:1d
r-This type of inputLis. applicable when.the conditions described above' for-proportional input are not satisfied."
l Reference 14: " Seismic Analysis of Multiply . Supported: Piping Systems," ,
EPRI NP-6153, Project 964-10, March 1989, Westinghouse Electric Corporation.
L DSER Open Issue 29: Combination of inertial responses and' seismic anchor movements (3.9.2.3). ;
1
Response
l l
Subsection 3.7.3.9.C of RESAR-SP/90 PDA Module 7,- " Structural / Equipment i Design," has been revised as shown below to state that inertial responses d calculated by the envelope response spectra method are combined with SAM by the absolute sum method.
"The results of modal envelope seismic spectra analysis.in Item A.1 above and the results of seismic anchor motion analysis in' Item B above are combined by the a.bsolute sum method when required by consideration of the ASME classification of stress. The results- of- the modal non-uniform saismic.
spectra results in Item A.2 above and the results of seismic anchor motion analysis in Item B above are combined by the SRSS.methe DSER Open Issue 30: Damping values for systems. with flexible in-line building-mounted equipment (3.9.2.2).
Response
Page 3.9-57 of Subsection 3.9.3.1.1.2B. of RESAR-SP/90 PDA Module 7,
" Structural / Equipment Design," has been revised as shown below to clarify the Westinghouse position.
WAPWR-DSER 21 JUNE 1989 L5978e:1d
"The damping values for auxiliary piping systems are shown in Table 3.9-6.
Piping systems with different nominal diameters and different damping characteristics are evaluated using the methods of Subsection 3. 7. 3. '.5.
Alternatively, the damping values in Figure 3.7-8 may be used. When Figure 3.7-8 is used, energy absorbing supports are not used for auxiliary piping systems. Figure 3.7-8 is applicable to piping systems which have flexible in-line components and flexible building mounted components, such as valves and tanks, respectively."
DSER Open Issue 31: Flow-induced vibration testing for non prototype plants (3.9.2.3).
Response
Subsection 3.9.2.4 of RESAR-SP/90 PDA Module 5, " Reactor Systems," has been modified to show that the hot functional testing for each SP/90 plant will be performed in accordance with the applicable guidelines of Regulatory Guide 1.20 for non prototype plants.
DSER Dpen Issue 32: Flow-induced vibration testing without dummy core (3.9.2.3).
Resoonse:
At this time, only a scoping analysis for the preoperational flow-induced i vibration test program for the first SP/90 reactor internals has been performed. This study has indicated that it may not be necessary to have a dummy core in place; however, given the preliminary nature of this study no firm decision on the presence of a dummy core has been made at this time.
As part of the detailed design phase, Westinghouse will perform a more extensive analysis to determine the requirements (test conditions, instrumen-l tation, etc.) for the preoperational flow-induced vibration test program in WAPWR-DSER 22 JUNE 1989 E978e:1d
,y general, and the need for a dummy core.in particular. If as a result of this study it is determined that a dummy core is not required, the justification for that decision will be included in the RESAR-SP/90 FDA application.
Subrection 3.9.2.4 of RESAR-SP/90 PDA Module 5, " Reactor System", has been modified to reflect this commitment.
DSER Open Issue 33: Design of reactor internals (3.9.2.3).
Response
The LOCA and seismic. safe shutdown earthquake (SSE) loads are combined by the square root sum of the squares (SRSS) method. The second paragraph of Subsection 3.9.2.5 (Page 3.9-3) of RESAR-SP/90 PDA Module 7, " Structural /
Equipment Design," has been revised to read as follows: "A digital computer program (1)', which was developed for the purpose of calculating local fluid pressure, flow, and density transients that occur in pressurized water reactor coolant systems during a LOCA; or other evaluation methods will be used to evaluate the structural effects on the reactor internals of the pipe breaks
! postulated for the SP/90P) .
The reactor internals important to safety were evaluated to withstand the combined loads resulting from a simultaneous loss-of coolant accident (LOCA) and safe shutdown earthquake (SSE). This combination was performed by the SRSS method, square root sum of the squares.
The results of these evaluations will be provided in the RESAR-SP/90 FDA document "
i l
WAPWR-D3ER 23 JUNE 1989 B978e:1d i
DSER Open Issue 34: Stress limits for Class 2 and Class 3 valves (3.9.3.1).
i 1
Response
1 Table 3.9-4 (not Table 3.9-5) of RESAR-SP/90 PDA Module 7, " Structural /
Equipment Design," shows stress criteria for Class 2 and 3 components. Table h s
3.9-4 has been revised to include valve discs along with valves for the )
various service levels.
DSER Open Issue 35: Design criteria for heating, ventilation, and air conditioning (HVAC) ductwork and supports (3.9.3.1).
~
Response
The AISC code used for qualification of the supports has been changed from AISC-N690 to AISC S326 since the AISC-N690 code for safety related structures has not yet been endorsed by the staff. The approach is thus consistent with the design criteria for structural steel described in Subsection 3.8.4 of RESAR-SP/90 PDA Module 7, " Structural / Equipment Design," with the added reference to the AISI code which covers thin steel members.
DSER Open Issue 36: Pipe support base plate and anchor bolt design (IE 3 Bulletin 79-02) (3.9.3.1).
Response
IE Bulletin 79-02 provided requirements for expansion anchor bolts for wedge, sleeve and shell anchors. Where such expansion anchor bolts are used in RESAR-SP/90, Westinghouse will comply with IE Bulletin 79-02.
Westinghouse plans to maximize the use of cast-in place anchorages such as 1
embedment plates and inserts. Where post-installed systems are required due l to late design information or changes, preference will be given to use of undercut anchors for significant loads. Such anchors were developed subsequent WAPWR-DSER 24 JUNE 1989 B978e:1d
s
]
1 to the issue of IE Bulletin 79-02 and . comply with the requirements for 'a ductile failure _ mode imposed in ACI 349, Appendix B. . Cast-in place embedments ;
and undercut anchors will be designed to the requirements of ACI 349, Appendix B. The alternative design requirements of paragraph B7.2 for expansion anchors not meeting the ductile failure mode requirements of Appendix B will not be used, and such expansion anchors will comply with IE Bulletin 79-02.
DSER Open Issue 37: Thermal stratification in unisolable piping (3.9.3.1).
)
Response
)
-The paragraph below has been added (following the first paragraph on page 3.9-57a) to Subsection 3.9.3.1.1.2.D of RESAR-SP/90 PDA Module'7, " Structural /
Equipment Design":
" Transients are also defined in branch lines which may be subject to cyclic and static thermal stresses as a result of valve leakage or inadequate mixing of hot and cold fluids. An ' alternative to thermal j stress analysis for valve leakage is implementation of: appropriate I pressure and temperature monitors to verify that significant--leakage does i not occur." l DSER Open Issue 38: Preservice/ Inservice pump and valve test program (3.9.6). i
Response
Based on discussions with the NRC project manager on SP/90, this open issue was erroneously identified as such and does'not require any action on -the part '
of Westinghouse. It will be removed from the staff's final SER for the SP/90 PDA.
.j WAPWR-DSER 25 JUNE 1989 E97Be:1d
i DSER Open Issue 39: Testing difficulties for inservice pump and valve testing ;
(3,9.6).
Response: !
The questioned ~ statement concerning valve testing referred to valves-involved with the safety injection function. ' Generically for the SP/90 design all remote safety-related valves cannot be exercised / tested to ASME~ Section XI requirements during full ~ power operation. Valves which should not b'e tested j include: 1) valves providing the RCS pressure boundary. such ~as' the RHR suction isolation valves; 2)'the pressurizer PORV's - and emergency letdown ;
isolation valves; 3) the steam generator -PORV's; 4) valves whose operation
.would result in plant transients-such as the main steam isolation valves, main i feedwater isolation valves, CVCS -letdown isolation valves, steam generator-blowdown isolation valves and reactor coolant p. ump seal injection isolation _ j valves. However, it should be noted that all remote safety related valves 'for l the safety injection and emergency feedwater system functions can- be exercised / tested in accordance with ASME Section XI requirements at full power. J The statement that full flow is provided through the " pumped ECCS flowpaths..." is correct. During RHR cooldown the RHR flowpath. includes'the !
four RHR heat exchanger and reactor vessel ' injection paths. Following cooldown during the refueling shutdown, all four HHSI pumps would be tested at !
full flow taking suction from the EWST and returning water to the EWST via the I full flow test line downstream of the RHR heat exchangers- -
1 DSER Open Issue 40: Conformance with_ Institute of Electrical and Electronics-Engineers (IEEE) Standard 344-1987 and Regulatory Guide (RG) 1.100, Revision 2 (3.10.1,3.10.2).
Response: i Westinghouse does not have a position on the IEEE Standard 344-1987 and .
Regulatory Guide 1.100, Revision 2, however, review of those documents will i 1
.WAPWR-DSER 26 JUNE 1989 I B978e:1d ;
i
begin shortly to establish a. generic position on their application in the seismic qualification of electrical and mechanical equipment. Our final position will not be available prior to receipt of the expected PDA, although we will meet the intent of the recommendations set forth in the~ subject documents. It is possible that in some areas it may prove .more reasonable to provide justification for applying the existing results of test methods considered to be more conservative.
The affected sections of RESAR-SP/90 PDA Module 7, " Structural / Equipment Design," will be revised during the final design phase to reflect our position.
DSER Open Issue 41,: Equipment qualification (3.11).
Response
Reference 1 of Subsection 3.11 -
WCAP-8587, Revision 6. " Methodology for Qualifying Westinghouse WRD Supplied NSSS Safety Related Electrical Equipment," cated November 1983, does not explicitly reference all the required codes and regulations that are discussed in this open issue.
However, the NRC Safety Evaluation Report (SER), dated November 1983, approving this report, concludes that the report complies"...with the NRC environmental requirements as codified by 10CFR50, Section 50.49 and its subordinate reguistory guides, NUREGs and IEEE Standards. -They comply with the NRC seismic requirements codified in Appendices A and B to 10CFR50, and
. Appendix A to 10CFR100, and its subordinate Regulatory Guides, NUREGs, and IEEE Standards." Westinghouse will revise WCAP-8587 to update our methodology for the qualification of safety related electrical equipment at the time we are closer to ordering equipment. Subsection 3.11 of RESAR-SP/90 PDA Module-7, " Structural / Equipment Design," will be modified during the final design phase to specifically reference the latest codes and standards used in the SP/90 design. Those codes will meet the requirements of 10CFR50, Appendices A and B, and 10CFR100, Appendix A.
WAPWR-DSER 27 JUNE 1989 5978e:1d
-_ _- _ -