TXX-4426, Application to Amend CPPR-127,requesting Exemption from Requirement for Protection from Dynamic Effects Associated W/Eight Postulated Primary Loop Pipe Breaks.Fee Paid

Application to Amend CPPR-127,requesting Exemption from Requirement for Protection from Dynamic Effects Associated W/Eight Postulated Primary Loop Pipe Breaks.Fee Paid

ML20112A351
Person / Time
Site:	Comanche Peak
Issue date:	03/12/1985
From:	Spence M TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Harold Denton Office of Nuclear Reactor Regulation
References
TXX-4426, NUDOCS 8503180273
Download: ML20112A351 (4)

Text

'

. Log # TXX-4426 File # 10101

. TEXAS UTILITIES GENERATING COMPANY 903.6 clo MKYWAY TE DWEN . 4tHP NOHTH OLIVE 9)TR EET, L.II. Mt

• DA LLAt* TEX AM 7520t March 12, 1985

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Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION DOCKET N0. 50-446 REQUEST FOR PARTIAL EXEMPTION FROM GENERAL DESIGN CRITERION 4 AND AMENDMENT OF CONSTRUCTION PERMIT CPPR-127

Dear Mr. Denton:

By letter dated August 28, 1984, the NRC granted Texas Utilities Generating Company (TUGCO) a partial exemption to General Design Criterion 4 of 10 CFR Part 50, Appendix A. This exemption eliminated the need to install jet impingement shields associated with postulated pipe breaks in eight (8) locations per loop in the Unit 1 primary coolant system main loop piping.

By letter dated October 26, 1984, the NRC amended the CPSES Unit 1 Construction Permit CPPR-126 to incorporate this partial exemption.

TUGC0's original exemption request was limited to only the jet impingement shields for Unit 1. We request here further exemption for Unit 2. The Westinghouse reports, WCAP-10527 (Proprietary) and WCAP-10528 (Non-proprietary), submitted by TUGC0 letter TXX-4158 dated April 23, 1984, and other analyses referenced in these reports, provide the bases for obviating the requirement for protection of structures, systems and components from all dynamic effects associated with the postulated pipe breaks (i.e., missiles, pipe whipping and discharging fluids) at CPSES Units 1 and 2.

Texas Utilities Generating Company hereby requests an exemption, pursuant to 10CFR50.12(a), for CPSES Unit 2 from the requirement for protection from the dynamic effects associated with the eight postulated primary loop pipe l breaks as follows:

Eliminate the need to design structures, systems and components for pipe whip, jet impingement, and the asymetric effects of cavity pressurization due to primary loop pipe breaks.

- Eliminate the need to install pipe whip restraints (including shims) and jet impingement shields on primary loop piping associated with the k eight primary loop pipe break locations defined in TUGC0 letter  ; gd8 TXX-4159 dated April 23, 1984. L3 8503180273 850312 ()0l W t phg;0 PDR ADOCK 05000446 A PDR A DIVIN10N OF TEXAN l'TRLETIEN ELL.TRIC COMi*ANY

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. Eliminate primary loop LOCA load evaluation on primary components, primary loop piping, branch line piping, and branch line supports l (branch line LOCA loads would be retained in the design basis). '

Granting of the requested exemption would not affect the following:

- ECCS design bases Containment and compartment design bases

- Equipment qualification bases

- ESF systems response Design of RCS heavy component supports The safety related auxiliary piping (piping attached to the RCS) and associated supports were originally designed for loop displacement effects of the main coolant pipe ruptures in addition to the auxiliary line pipe ruptures, if this request is granted the new basis for the as-built reconcilation analysis will be the loop displacement effects of the worst case remaining ruptures in the auxiliary system piping.

As previously discussed in TUGC0 letter TXX-4118 dated February 17, 1984, the CPSES Reactor Coolant Pressure Boundary Leak Detection Systems meet the guidelines of Regulatory Guide 1.45.

NRC acceptance of this exemption request will result in significant benefits in terms of (a) cost savings attributable to construction / installation of restraint shimming and deflectors, and (o) reduced occupational radiation exposure and cost saving over the life of the unit. in order to realize these benefits, Texas Utilities Generating Company requests the NRC to review and approve this exemption request by May 1, 1985.

The Value Impact Analysis for this request was previously s;bmitted by TUGC0 letter TXX-4159 dated April 23, 1984, in support of the exemption request for Unit 1. This Value Impact Analysis was performed for both CPSES Units 1 and 2, and is now being used in support of this exemption request for Unit 2.

If this request is granted, Texas Utilities Electric Company additionally requests that the Unit 2 Construction Permit CPPR-127 be amended to reflect the above partial exemption upon its issuance.

Paragraph 3 of the Construction Permit states, in pirt as follows:

This permit shall be deemed to contain and be subject to the conditions specified in Section 50.54 and 50.55 of said regulations; is subject to all applicable provisions of the Act, and rules, regulations, and orders of the Commission now or hereafter in effect; ...

We request that Paragraph 3 be amended by inserting ", as modified by duly authorized exemptions" after the words "in effect" and before the semicolon.

L

I We also request that Paragraph 3.C. of the Construction Permit be revised by inserting the parenthetical phrase and the word "in" after the word "and", as follows:

. . . construct the facility described in the application (as modified by duly authorized exemptions) and in the hearing record, in accordance . . .

Attached is an affidavit in accordance with 10 CFR 50.30(b). Also enclosed in accordance with 10 CFR 170.12 is a check in the amount of $150.00 as payment of the application fee.

We remain available to meet with the Staff to resolve any questions which may arise and provide any information necessary to implement this request promptly. The FSAR will be amended to reflect the revised design bases for the above mentioned items once the exemption is granted.

Respectfully, n -v &

M. D. Spence BSD/grr Attachment Enclosure Distribution: 3 signed and sworn originals plus 40 copies L . .. .. .. . . . . . .. . .

1

-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'In the Matter of )

)

TEXAS UTILITIES ELECTRIC COMPANY ) Docket Nos. 50-446

)

(Comanche Peak Steam Electric )

Station, Units 1 and 2) )

AFFIDAVIT Michael D. Spence being duly sworn, hereby deposes and says that he is President of Texas Utilities Generating Company, a division of Texas Utilities Electric Company, the Applicant herein; that he is duly authorized to sign and file with the Nuclear Regulatory Commission this request to amend the Construction Permit (CPPR-127) for the captioned facilities; 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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. 14_ _ -y_=__-

Michael D. Spence President STATE OF TEXAS )

) ss

. COUNTY OF DALLAS )

Subscribed and sworn to before me, a Notary Public in and for / /iv ,

on this g day of Ala (el , 1985.

b Notary Public My commission expires ugetIn13,193

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