ML20113E054

Affidavit of J Doyle Re Case Answer to Applicant Motion for Summary Disposition Re Local Displacements & Stresses. Certificate of Svc Encl

ML20113E054
Person / Time
Site:	Comanche Peak
Issue date:	01/05/1985
From:	Doyle J Citizens Association for Sound Energy
To:
Shared Package
ML20113D985	List: ML20113D972 ML20113E013 ML20113E054
References
OL, NUDOCS 8501230291
Download: ML20113E054 (5)

Text

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- ~. e ? ;C 3 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION c: so 09 qq ;59 BEFORE THE ATOMIC SAFETY AND LICENSING" BOARD In the Matter of l -

t;DQCket.Noss150-445 l 0C:4.0 ,

< and 50-446 TEXAS UTILITIES ' ELECTRIC i COMPANY, et al. . l l (Application for an (Comanche Peak Steam Electric l Operating License)

Station, Units 1 and 2)

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l SUPPLEMENT TO CASE'S ANSWER TO APPLICANTS' MOTION FOR

SUMMARY

DISPOSITION REGARDING LOCAL DISPLACEMENTS in the form of AFFIDAVIT OF CASE WITNESS JACK D0YLE Q: Is there new and significant information which you want to call to the attention of the Board?

A: Yes. It is SSINS No. 6835, IN 84-87, NRC Information Notice'No. 84-87:

" Piping Thermal Deflection Induced by Stratified Flow," December 3, 1984 (copy of which is attached).

As argued by CASE time after time in answer to Applicants' introduction of procedures to ' justify constraint of thermal growth and movement of the pipe within the support, time is the critical element for determining maximum temperature differential between heated and unheated elements. Applicants should have been using Fourier field equations based on time rather than the steady state formulas for the final st' ate of equilibrium. This can best be noted in tre attached NRC Information Notice No. 84-87, " Piping Thermal Deflect. ion Induced by e

0 5 85012302{1 PDR ADOC PDR G 1

1s Stratified Flow," December 3, 1984, where o,n August 22, 1984, at WNP-2, 15 minutes after cool fluid was introduced into a hot pipe, the cool fluid caused a temperature differential between the top and bottom of the-pipe, resulting in a displacement of the pipe which caused severe damage to several feedwater pipe hangers and snubbers.

This clearly indicates that a temperature equalibrium between the

~ cool fluid and the hot pipe had not occurred within this 15-minute time frame. This condition was initially assumed to have been a water hammer by the utility. However, later it was found to be the result of thermal deflection induced by stratified flow (constraint of free-end displacement).

As CASE has constantly argued and is shown-by-this Information Notice, it is not the equalized thermal end condition which is important to support-design, but rather-it is the maximum differential condition which occurs in the interim between the initial condition and the end condition.-

-Additionally,' Applicants, in their analysis to prove that the induced _ stresses were within allowable,_ failed to follow the procedures as set forth in ASME Section III, NB, NC, and ND 3611, relative to thermal-cyclic loading, which may have a profound ef fectron equation 11-

-(from NB, NC, and ND 3653),'which is already marginal in the 7,000

^

. cycle range.- .Also, Applicants failed to include the provisions of Welding Research Council (WRC) Bulletin 107 of August 1965 " Local

' Stresses in Spherical and ' Cylindrical Shells Due to External Loadings," '

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by Wichman, Hooper, and Hershon.

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I have read the foregoing affidavit, which was prepared under my personal

- direction, and.it is true and correct to the best of my knowledge and belief.

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. Date: r k n A' /YWf 4

STATE OF M'{'

COUNTY OF l/ N'fl)&-;/$

On this, the Y day of JAM /' ,198[ personally appeared

- /tCN ' b '/ L G , known to ne to be the person

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whose name is suoscribed to the foregoing instrument, and acknowledged to me that he/she executed the same for the purposes therein expressed.

Subscribed and sworn before me on the 6 TA day of sl/hNMT ,

198[

Y6M+Lu.,k ft and for the State of Notary IIJMc Public)c a H09e i 15 My Commission Expires: O T . dl., /9fD W5-

SSINS No. 6835 IN 84-87 UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND INFORCEMENT WASHINGTON, D. C. 20555 December 3,1984 INFORMATION NOTICE NO. 84-87: PIPING THERMAL DEFLECTION INDUCED BY STRATIFIED FLOW Addressees:

All nuclear power reactor facilities holding an operating license (0L) or construction permit (CF).

?uroose:

This notice is provided to inform licensees and applicants of a recent event that demonstrates a previously unidentified mechanism for piping system and pipe support damage. Recipients are expected to review the information for applicability to their facilities.and consider actions, if appropriate, to preclude similar problems occurring at their facilities. However, suggestions contained in this information notice do not constitute NRC requirements; therefore, no specific action or written response is required.

Descriotion of Circumstances:

On August 22,1984, WNP-2 experienced a thermal transient that damaged a portion of the feedwater system. Following an outage of about 5 days, the plant began to slowly admit feedwater to the reactor vessel with the reactor at about 1% power. About.15 minutes after beginning flow, the licensee heard a dull " thud" in the plant. The licensee found several feedwater pipe hangers and snubbers damaged and a flange loosened, allowing a small leak of feedwater.

The licensee reported the event to the NRC Operations Center as a " water hammer"; but after consulting with experts and considering other circumstances, the licensee determined that the event could be the result of a thermal

' deflection induced by stratified flow. In this type of transient, the plant's configuration and the slow admission of cold feedwater to a pipe filled with high temperature water causes stratified flow in the pipe with-cold water cooling the bottom of the pipe and hot water remaining in the top of the pipe.

The difference in temperature between the top and bottom of the pipe causes the pipe to bend and may pull hangers out of their supports.

An unusual design feature of the WNP-2 plant allows the feedwater system to be heated by the reactor water cleanup system (RWCUS). The RWCUS return lines join two 24-inch feedwater lines upstream of two isolation check valves, but downstream of normally open motor-operated valves. In many boiling water reactors, the RWCUS enters the feedwater system between the inboard and out-boarc isolation check valves so that reverse flow of the RWCUS into the feedwater. system is not pos:ible.

MC03C.0L)

IN 84-87 December 3, 1984 Page 2 of 3 (Ehen the RWCUS is operating at WNP-2, but feedwater is not, flow is insufficient to open both sets of check valves. Some of the SWCUS return flows in the reverse direction back into the feedwater system before returning to the vessel. Consequently, during hot standby, the RWCUS flow heats a long run of horizontal feedwater piping. When a low rate of feedwater flow is initiated, the cold feedwater (a' bout 100 F) flows along the bottom of the pipe. The pipe anding phenomenon occurs because of the large temperature difference between

.he top of the pipe (previously heated to about 400 F by the RWCUS flow) and 1e bottom of the pipe cooled by the feedwater. Any system configuration and

, cerating conditions where stratified flow can cause large temperature differences between the top and bottom of a pipe could produce the pipe bending phenomenon.

Following the event on August 22, 1984, the licensee instrumented the feedwater line to detect and record pipe movement and differences in temperature between the top and bottom of the pipe. The additional instrumentation for detecting and recording pipe movement was installed both in positions that were suspected of moving sucn as at a hanger that failed, and in positions that were suspected of not moving such as at a hanger that was believed to be acting as a fulcrum.

Despite procedures designed to preclude recurrence of the event, the event occurred again following a scram from 60% power on September 10, 1984. Because of the instrumentation on the feedwater lines the licensee can exclude other explanations for the phenomenon, such as water hammer.

Discussion:

The licensee's investigation of this complex phenomenon is detailed in a report titled " Design Engineering Report, WNP-2 Feedwater Thermal Deflection Events"

-and will not be repeated here. Copies of the report may be obtained from:

Mr. P. L. Powell ,- Manager WNP-2 Licensing Washington Public Power Supply System-P. O. Box 968-3000 George Washington Way Richland, Washington 99352.

Although this report-is useful as a description of the event, the NRC has not evaluated the report and does not necessarily endorse all of the conclusions of

the report.-

-Other licensees may wish to consider whether events that are apparently water hammer are caused by a pipe bending phenomenon similar to that which has occurred at WNP-2. Any time a licensee slowly feeds cold water into a hot

-filled pipe there may be the potential for this type of event.

There are several reasons why licensees may wish to determine if some apparent water hammers are really a thermal-gradient-induced pipe bending phenomenon:

1. Piping systems can be designed to accommodate this phenomenon without damage, thereby preventing further events. Repositioning, strengthening, or nodifying pipe supports or hangers and snubbers rmy allow for pipe movement. -

t s Attachment IN 84-87 December 3,1984 LIST OF RECENTLY ISSUED l IE INFORMATION NOTICES  !

i Information Dakeof l Notice No. Subject Issue Issued to  !

' )

86 Isola' tion Between Signals 11/30/84 All boiling water of the Protection System reactor facilities '

and Non-Safety-Related holding an OL or CP i Equipment 84-85 Molybdenum Breakthrough 11/30/84 All NRC licensed from Technetium-99m medical institutions Generators and radiophamaceutical suppliers 84-84 Deficiencies In Ferro- 11/27/84 All boiling water Resonant Transformers reactor facilities holding an OL'or CP

. 84-83 Various Battery Problems 11/19/84 All boiling water reactor facilities holding an OL or CP 82- - . Guidance for Posting 11/19/84-- All boiling water j . Radiation Areas reactor facilities .

holding an OL or CP 84 Failures of.Rockwell 11/16/84 All boiling water reactor facilities

Supp. 1 International Globe Valves

- holding an OL or CP 84-81 Inadvertent Reduction In 11/16/84 All boiling water

! Primary Coolant Inventory In reactor facilities Boiling Water Reactors During holding an OL or CP Shutdown and Startup 84-80 Plant Transients Induced by 11/8/84 All B&W power reactor Failure of Non-Nuclear facilities holding Instrumentation Power an OL or. CP 79 Failure 4to Properly Install 11/5/84 All boiling water Steam Separator at Vemont -reactor facilities- *

! . Yankee ~

holding an OL or CP

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= 84-78 . Underrated Teminal Blocks 11/2/84 ~All power reactor that may-Adversely Affect . facilities holding i 10perations of Essential. an OL or CP -

Electrical Equipment .

.,0L.= Operating License CP = Construction Pemit .

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IN 84-87 December 3,1984 Page 3 of 3 2.

be within the design capacity of the pipes.'The stresses on the

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stratified flow) Changes to operating procedures may prevent pipe No specific action or written response is required by this iriformation notice If you have any questions about this matter, please contact the Regional .

. Administrator of the appropriate regional office or this office.

11Y_:

Edward . Jordan, Director Divisi of Emergency Preparedness and Engin ering Response Office of Inspection and Enforcement Technical ~ Contact- Eric Weiss, IE (301)'492-9005

Attachment:

List of Recently Issued IE Information Notices s

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i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the-Matter of- }{

}{

TEXAS UTILITIES ELECTRIC }{ Docket Nos. 50-445-1 COMPANY, et al. }{ and 50-446-1 (Comanche Peak Steam Electric }{

Station, Units 1 and 2) }{

CERTIFICATE OF SERVICE By my_ signature below, I hereby certify that true and correct copies of CASE's- 1/17/85 Supplement to CASE's Answer to Applicants' Motion for Summary Disposition Regarding Local Displacements and Stresses have been sent to the names listed below this 17th day of January ,198_5, _

'by: Express Mail ~ where indicated by

• and First Class Mail elsewhere.

• dministrative Judge Peter B. Bloch

• Nicholas S. Reynolds, Esq.

U. S. Nuclear. Regulatory Commission: -Bishop, Liberman, Cook, Purcell 4350_ East / West Highway, 4th Floor

& Reynolds Bethesda, Maryland 20814' 1200 - 17th St., N. W.

Washington, D.C. 20036

• Judge Elizabeth B. Johnson

-Oak Ridge National Laboratory-

• Geary S. Mizuno, Esq.

. P. O. Box X, Building 3500 Office of Executive Legal

{0ak Ridge, Tennessee 37830- Director

'U. S. Nuclear Regulatory

'* Dr. Kenneth A. McCollom, Dean Commission

, Division of Engineering, Maryland National Bank Bldg.

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Architecture-and Technology - Room 10105 Oklahoma' State, University 7735 Old Georgetown Road Stillwater, Oklahoma- 74074 Bethesda, Maryland- 20814

• Dr. Walter H.: Jordan Chairman, Atomic

• Safety and Licensing Carib Terrace Mote 1~ Board Panel' U. S. Nuclear Regulatory Commission 552 N Ocean ~ Blvd.-

l Pompano Beach, Florida 33062 Washington, D. C. 20555' i

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Chairman Renea Hicks, Esq.

Atomic Safety and Licensing Appeal Assistant Attorney General Board Panel Environmental Protection Division U. S. Nuclear Regulatory Commission Supreme Court Building Washington, D. C. 20555 Austin, Texas 78711 Mr. Robert Martin Anthony Z. Roisman, Esq.

Regional Adminigtrator, Region IV Trial Lawyers for Public Justice i U. S. Nuclear Regulatory Commission 2000 P Street, N. W., Suite 611 611 Ryan Plaza Dr., Suite 1000 Washington, D. C. 20036 Arlington, Texas- 76011

• Mr. Owen S. Merrill Lanny A. Sinkin Staff Engineer Executive. Director. Advisory Committee for Reactor Nuclear Information and Resource Safeguards (!!S H-1016)

Service U. S. Nuclear Regulatory Commission 1346 Connecticut Avenue, N. W., Washington, D. C. 20555

'4th Floor .

Washington, D. C. 20036 Dr.' David H. Bolt:

2012 S. Polk Dallas, Texas 75224 Michael D. Spence, President-Texas Utilities Generating Company Skyway Tower 400 North Olive St., L.B. 81 Dallas, Texas '75201 Docketing and Service Section (3. copies) ,

Office of the Secretary U. S. Nuclear. Regulatory Commission Washington, D. C.. 20555 in,W 0A T >

' y s.) Juanita Ellis, President CASE (Citizens Association for Sound Energy)

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1426.S. Polk Dallas, Texas 75224 214/946-9446 r .

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