ML19326D442

Forwards Positions Re Implementation of Reg Guides 1.20, 1.26,1.29,1.46,1.48,1.67,1.72 & 1.40.Reg Guides on Agenda for Mechanical Engineering Reg Guide 751118 Meeting.Reg Guide 1.40 on Agenda for Electrical Control Sys Meeting

ML19326D442
Person / Time
Site:	Midland
Issue date:	10/10/1975
From:	Bauman R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Boyd R Office of Nuclear Reactor Regulation
References
NUDOCS 8006110464
Download: ML19326D442 (15)

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Director of Nuclear Reaction Regulation '

[ 1 Attn: Mr. Roger Boyd, Acting Director

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U.S. Nuclear Regulatory Co= mission e~ fI Vashington, D.C. 20555 D - /g8s[ O' ,d '

\'n MIDLAND PROJECT DOCKET NUMBERS 50-329, 50-330

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,(N N.'c.','q 7g e REGULATORY GUIDE ESTINGS FILE: 0505 SERIAL: 1856 We are attaching herewith 10 copies of the Consumers Power Ccmpany positions on implementation of Regulatory Guides 1.20, 1.26, 1.29, 1.46, 1.48, 1.67 and 1.72.

These Regulatory Guides are on the agendc for discussion in the Mechinical l Engineering Regulatory Guide meeting which has been scheduled for November 18, 1975 by your staff. )

Also attached are 10 copies of the Consuner's position on implementation of Regulatory Guide 1.40. This Regulatory Guide has been removed from the agenda for the Mechanical meeting and placed on the agenda for the Electrical / Control Systems meeting scheduled for November 13, 1975 by your staff. It should be added to the set of positions transmitted with our letter of July 21, 1975.

THIS DOCUMENT CONTAINS P00R QUAUTY PAGES l R. C. Bauman Project Engineer ~~'

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REGULATORY GUIDE 1.20 VIBRATION MEASUREMENTS ON REACTOR INTERNALS (December 29, 1971)

• For equipment within the B&W scope of supply, the degree of compliance with this Regulatory Guide is as follows:

The preoperational vibration monitoring program for these units will be in compliance.with parts d.1 and 2 of this guide. The prototype unit for these internals is the Oconee Unit 1. This test program is described in B&W topical reports BAW-10038, " Prototype Vibration Measurement Program for Reactor Internals," Rev. 1, November 1972, and BAW-10039,

" Prototype Vibration Measurement Results for B&W's 177-Fuel Assembly 2 Loop Plant," April 1973.

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a REGULATORY GUIDE 1.26 QUALITY GROUP CLASSIFICATION AND STANDARDS (June 1975)

RESPONSE TO RI:GULATORY POSITION Quality group classifications and code requirements for components of plant prccess systems meet the intent of Regulatory Guide 1.26. Certain clarifications and specific exceptions to the guide are discussed below.

(1) Paragraphs A and B There is a different usage of the term "important to safety" than that used elsewhere in the regulations and regulatory guides. The guide includes components which fall into quality group D under the definition of "important to safety," which implies that a quality assurance program in accordance with 10 CFR Part 50, Appendix B, should be applied. Quality assurance require-ments are not applied to quality group D components.

The definition of the term "important to safety," insofar as quality assurance is concerned, is considered to be that which appears in the introduction of Regulatory Guide 1.29.

(2) Midland quality group classifications are reflect.ed in PSAR Figure 4.1-1 submitted to the NRC by Amendment No. 26. We are aware of the following open items as discussed in the November 1, 1974 letter from A. schwencer (NRC) to S. H. Howell (CPCo) :

a. The feedwater ring header is ANS'I B31.1.0 vs ASME III-2. This is due to the fact that this component was purchased in 1968.

b. Portions of the reactor coolant pump seal injection system are ASME III-3 vs ASME III-2. These lines were designated ASME III-3 because they fall under the requirements of Regulatory Guide Position C-2.b.

c. Except for ASME Section III Class 3 piping to the first isolation valve of the RCP seal cooler /

motor cooler, the CCW supply pipe is B31.1 to the RCP coal cooler / motor coolcr, the letdown cooler and the seal return cooler. As indicated in PSAR section 4.2.2.4, loss of CCW to the RCP seals does not preclude cooling of the seals since seal

' injection water is available. Also, as discussed in 4.2.2.4, loss of CCW to the seal return coolers does not affect operation of the RCPs.

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G REGULATORY GUIDE'l.26 (cont'd)

The letdown line is not necessary following a LOCA,-and is isolated through the use of an ECCAS signal. The letdown coolers are not sized to handle any significant cooling (16 x 10 6 Btu /hr with a log mean temperature difference (LMTD) of 124 0F.) Follow-ing a LOCA, the RC temperature would drop rapidly which decreases the temperature difference and the heat transferred by this cooler. The decay heat coolers are sized to handle 30 x 106 Btu /hr at an LMTD of 15.

Even for the case where the RC pressure stays up follow-ing a LOCA,,the decay heat pumps would be used as booster pumps for the makeup pumps with the decay heat coolers handling the recirculation flow adequately, even assuming a single failure. At the present time our system controls do not allow the H.P. pumps to take suction from the makeup tank following a LOCA.

Thus, it would be difficult to use the letdown coolers as a backup for the decay heat coolers.

d. In addition we'wish to clarify one area of possible misinterpretation on Figure 4.1-1. The piping in the.

chemical addition system from the tanks to the pumps and from the pumps to the makeup and purification

' system is designed to ANSI B31.1.0. This is not clearly indicated on' Figure 4.1-1. This classification is made since this system does not serve a safety function.

The quality group B seismic Class 1 BWSTs provide the

. boric acid required to bring the reactor to a cold shutdown condition.

(3) Position Col.d The words "or remote manual" are considered to be inserted after the word " automatic" in the seventh line of the paragraph. This option is included to avoid an unnecessary complication (leading to decreased plant reliability) in lines which would not normally be provided with automatic closing valves.

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REGULATORY GUIDE 1.26 (cont ' d)

(4) Position C.2.c -

Systems connected to the reactor coolant pressure boundary are quality group D beyond the second isolation valve that is either normally closed or capable of automatic or remote manual closure.

(5) Position-C.2.d and e Radioactive waste systems and other systems "that contain or may contain radioactive material," are divided between quality groups C and D based on an offsite dose resulting from failure of components in the systems. The dividing line value of 0.5 rem, which appears to be based on,the normal annual release limits of 10 CFR Part 20, is inappropriate for the types of failures which the guide is addressing. Quality group D is applied to such systems unless their failure would result in offsite doses approaching the guideline values of 10 CFR Part 100.

(6) Amendment 30 to the Midland PSAR discusses the use of concrete pipe in a portion of the ultimate heat sink. -

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REGULATORY GUIDE 1.29 SEISMIC DESIGN CLASSIFICATION (August 1973)

RESPONSE TO REGULATORY POSITION Seismic design classification for plant structures, systems, and components meets the intent of Regulatory Guide 1.29.

In order to meet the intent of the Regulatory Guide, certain clarifications.of the guide are necessary. The following items describe these clarifications and specific exceptions to the guide.

(1) As indicated in the introduction section of.the guide all plant items important to safety should be designed for a safe shutdown earthquake. (SSE) .* All plant items which are necessary to cope with a loss of coolant accident '(LOCA) or to shut the plant down saf31y following an SSE in the absence of.a LOCA are designed for the SSE. There are,

'however, some plant items not required following an SSE but which are required to cope with other natural phenomena.

For example, a plant item which is required to function only during or following a tornado in order to achieve a safe plant shutdown must be considered important to safety.but design of the item for,an SSE is unnecessary.

Further, there are plant items which serve to mitigate the consequence of certain in-plant occurrences (other than LOCA) which are not considered to occur simultaneously with an SSE. Examples of the latter are fuel handling or spent fuel cask accidents and loss of control room habitability. This point.does not conflict with the regulatory position of the guide, but is noted here to clarify the. fact that certain items not listed in Regulatory Guide 1.29 are considered important to safety and therefore subject to quality assurance coverage in accordance with 10 CFR Part 50, Appendix B.

(2) Position C.l.d Systems required for reactor' shutdown or residual heat removal must be designed for the SSE. This is interpreted to' include only those minimum systems which must function in the performance of an orderly shutdown and in mainten-ance of the plant in'the shutdown condition. For the reasons

-stated in the response to Regulatory Guide 1.26 the cooling water to the letdown coolers is not designed to seismic Class 1 standards. The chemical addition system is not designed to r nn . - -

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REGULATORY GUIDE 1.29 (cont'd) seismic Class 1 requirements since the BWSTs can provide sufficient boric acid for reactor shutdown /cooldown after a seismic event. The water / boric a.cid in the nWST is used to complete an orderly feed without bleed shutdown /cooldown

.of the reactor plant in the event that the letdown system and chemical' addition systems are unavailable.

(3) Position C.l.f The words "or remote manual" are considered to be inserted after the word " automatic" in the eighth line of the paragraph. This option is included to avoid an unnecessary complication (leading to decreased plant reliability) in main steam branch lines which would not normally be provided with autcmatic closing valves.

(4) Position C.l.h Since the reactor coolant pumps do not perform any safety function, and since failure of the reactor coolant pumps due to cooling water system failure does not have safety implications (see PSAR Section 4.2.2.4) the cooling water

- system for the reactor coolant pumps is not designed to withstand an SSE.

(5) Position C.l.p and q These paragraphs cover radioactive waste systems and other systems "that contain or may contain radicactive material," and set a dividing line between seismic Category I and non-seismic Category I based on an offsite dose resulting from failure of components in the systems.

The dividing line value of 0.5 rem, which may be based on the normal annual release limits of 10 CFR Part 20, conflicts directly with the third paragraph of the introduction to the guide. Such systems are not designed for the SSE unless their failure would result in offsite doses approach-ing the guideline values of 10 CPP.Part 100.

(6) Position C.2 Portions of structures, systems, or components not designed as seismic Class 1 whose failure could reduce the function-ing of any safety related component to an unacceptable level will be analyred to insure that such failure will not occur under seismic loading.

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REGULATORY GUIDE 1.29 (cont'd)

(7) Position C.4 Quality assurance requirements of 10CFR50 Appendix B are not applied to components discussed in Position C.2 above.

(8) To clarify a point discussed in A. Schwencer's letter to S. Howell dated November 1, 1974, we point out that all ASME III Class 3 components designed and/or purchased to date are seismic Class 1.

• Thei term " Design Earthquake" used in the PSAR is also commonly called " Operating Basis Earthquake" and is equivalent to one-half of the " Safe Shutdoun Earthquake" (SSE) . The term " Maximum Earthquake" used in the PSAR and sometimes referred to as

" Design Basis Earthquake," is equivalent to " Safe Shutdown Earthquake."

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4 REGULATORY GUIDE 1.46 PROTECTION AGAINST PIPE WHIP INSIDE CONTAINMENT (May 1973)

RESPONSE TO REGULATORY POSITION The-requirements of the Regulatory Guide are met. The following clarifications are required to describe our analysis:

Paragraph B High energy fluid systems are defined as in APCSB 3-1 and MEB 3-1.

C.1 The B&W piping systems were designed in accordance with the ANSI B-31.7 Code. Break locations will be chosen utilizing the Regulatory Position for ASME Section III Code Class 1 piping.

C.l.b ASME Section III Code Class 1 piping breaks will be postulated to occur at any intermediate locations where th3 primary plus secondary stress intensities derived on in clastically calculated basis under the loadings associated with specified seismic events and normal plant conditions (plant operating conditions during reactor startup, operation at power, hot standby, or reactor cooldows to cold shutdown condition) exceed 2 Sm for ferritic steel and 2.4 Sm for austenitic steel.

. C.l.d Intermediate break locations for ASME Section III Code Class 1 piping, in addition to those determined by lb and 1c, will be selected on the basis of maxi- -

mum stress intensity or changes in the coordinate plane of the line. As a minimum, there will be two intermediate locations for each piping run or branch run.

C.2.c No fatigue analysis of ASME Section III Code Class 2 or 3 piping will be done.

C.2.d Intermediate break locations for ASME Section III Code Class 2 and 3 piping, in addition to those determined by 2b and 2c, will be selected on the basis of maximum stress intensity or changes in the coordinate plane of the line. As a minimum, there will be two intermediate locations for each piping run or branch run.

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REGULATORY GUIDE 1.46 (cont'd)

Footnote 10 - Break area for longitudinal breaks is assumed to be equal to the effective cross-

. sectional flow area upstream of the break only.

C.3 For that portion of the decay heat system which is high energy for only short operational periods, we will postulate critical cracks

• in lieu of cir-cumfere.ntial or longitudinal breaks.

• Critical cracks are assumed to be 1/2 the pipe diameter in length and 1/2 the pipe wall thickness in width.

On the topic of high energy line breaks we wish to obtain clarification of the Commission's statements 3 and 4 of A. Schwencer's October 18, 1974 letter to CPCo, a copy of which is attached.

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REGULATO,RY GUIDE 1.67 INSTALLATION OF OVERPRESSURE ,

PROTECTION DEVICES (October 1973)

RESPONSE TO REGULATORY POSITION Compliance with ASME Code Case 1569, " Design of Piping for Pressure Relief Valve Station," as supplemented by Regulatory Guide 1.67, is subject to the folicwing:

(1) The specifications are applicable to open discharge, simple configurations of stack, non-water seal and non-slug flow, relief or safety valves.

(2) Regulatory Position C.1 of Regulatory Guide 1.67 requires that the magnitude of the reaction force, the anticipated transient behavior, and the basis for theirspecification design determinationforshould be included in the the valve. Since all of the above are characteristic to each valve manu-facturer, it is not current practice to stipulate these data. Rather, the manufacturer supplies that information after selection of the valve, orifice size, inlet and outlet O.D., etc., to accommodate the flow rates required by the Design Specification.

This manufacturer supplied infcrmation is then used in the design of the relief / safety valve station.

(3) Response to Regulatory Position C.2 RV connections are spaced on the header so that there is no local interaction. The total forces and moments on the header resulting from simul-taneous discharge of all RVs are included in the stress analysis of the header and its supporting restraint system.

(4) Response to Regulatory Position C.3 The design of relief valve (RV) stations includes the considerations of both local stresses at the header-to-RV inlet piping junction and the stresses in the RV inlet piping and header.

(5) Response to Regulatory Position C.4 Forces and moments on the piping resulting from thrust developed by full opening of the RV are considered in the stress analysis. Dynamic Ampli-

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Response to Regulatory Position C.4 co'.?

c t fication factors are considered in the design.

The dynamic amplification factor is defined as '

the ratio of the actual deflection of the relief valve to the static deflection. The actual deflec-tion is calculated by modeling the valve header assembly as a single degree of freedom equiva? ant spring-mass system; the response due to the forced vibration is then calculated.

In lieu of the above procedure, some history-dynamic calculation may be uced.

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1 REGULATORY GUIDE 1.72 SPRAY POND PLASTIC PIPING .

RESPONSE TO REGULATORY POSITION

, Regulatory Guide 1.72 does not apply to the Midland facility since spray ponds are not used.

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. REGULATORY GUIDE 1.40 QUALIFICATION TEST OF CONTINUO *JS-DUTY MOTORS INSTALLED INSIDE Tile CONTAINMENT .

OF k'ATER-COOLED NUCLEAR P0k'ER PLANTS RESPONSE TO REGULATORY POSITION ,

The requirements of Regulatory Guide 1.40 are met as follows:

1. The reactor building cooler' motors are the only applicable motors in the Midland Plant.

2. To the extent practicable, auxiliary equipment that will be part of the installed motor assembly will also be qualified in accordance with IEEE Standard 334-1971.

3. The qualification will simulate as closely as practical all design l basis events which affect operation of the motor's auxiliary equipment.

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