ML20133H949

Forwards Proprietary Whipjet Program, Re Improved Means for Determining Necessity to Install Mechanical Devices to Protect Equipment & Structures from Effects of Pipe Breaks. Program Withheld (Ref 10CFR2.790)

ML20133H949
Person / Time
Site:	Beaver Valley
Issue date:	10/10/1985
From:	Carey J DUQUESNE LIGHT CO.
To:	Knighton G Office of Nuclear Reactor Regulation
Shared Package
ML19273A664	List: ML20133H949
References
2NRC-5-139, TAC-62883, NUDOCS 8510180193
Download: ML20133H949 (6)

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'A Duqu@esne Lidit zwem Nuclear Coristruction Division Telecopy 2 29 Ns'bu$h)A 552 5 October 10, 1985 United States Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Mr. George W. Knighton, Chief Licensing Branch 3 Office of Nuclear Reactor Regulation

SUBJECT:

Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 Alternate Pipe Rupture Protection Progran Gentlemen:

Enclosed herewith please find a copy of the "WHIPJET" program proposed by Duquesne Light Company (DLC) which provides an improved means for determining the necessity to install mechanical devices to protect equipment and structures from the effects of pipe breaks. This document provides a more definitive programatic technical description, including acceptance criteria, than the general program description which was submitted by letter 2NRC-5-128 dated September 6, 1985.

Initial regulatory consideration of pipe rupture (1974) arbitrarily assumed instantaneous full flow double ended pipe breaks.

During the last 10 years, the engineering discipline of fracture mechanics has improved substantially. It is widely accepted in the engineer-ing community that fracture mechanics will accurately predict the behavior of flaws and cracks in piping when applied correctly.

OLC proposes to provide pipe break protection at BVPS-2 using an alternate improved method. It is proposed to implement a comprehensive engineering program (WHIPJET) with main features as follows:

a. Using guidance from NUREG-1061, Vol. 3, show that conditions for applying fracture mechanics to Balance-of-Plant (B0P) postulated pipe breaks are satisfied,

b. Analyze BOP postulated breaks to show that even large flaws will remain stable and that leakage from such flaws can be detected before the pipe will break (LBB).

c. If for any systems, conditions for applying fracture mechanics are not met or LBB cannot be proven, then the conventional approach using whip restraints and jet shields will be used.

As discussed in the full description of the WHIPJET proposal, it is clear that the proposed approach will be a net safety benefit. OLC would \

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United States Nuclear Regulatory Commission Mr. George W. Knighton, Chief Alternate Pipe Rupture Protection Program Page 2 like the NRC to accept the general approach proposed herein subject to later detailed review and approval of the results of the tests and analysis per-formed as part of WHIPJET.

If the overall philosophy is accepted, the tests and analyses of systens would provide the improved means of pipe break protection alluded to in the first paragraph above for most of the postulated breaks.

There would be some breaks as discussed in (c) above for which the conventional approach would be used. Whip restraints and jet shields would be installed for these systens.

A schedular implenentation progran is hereby requested if it is deemed necessary to permit BVPS-2 to load fuel prior to installation of any pipe whip restraints determined necessary by this program.

The following overall schedule is proposed:

o DLC to perfonn the engineering COMPLETE tests and analyses of WHIPJET DEC 86 o NRC evaluate results of WHIPJET COMPLETE PRIOR TO ISSUANCE OF engineering tests and analyses LICENSE FOR FULL POWER OPERA-TION o DLC install any whip restraints DURING SCHEDULED REFUELING determined to be required as a OUTAGES result of WHIPJET analysis and/or NRC evaluation of WHIPJET results The progran has been discussed with menbers of the NRC staff. In addition, it was presented to a combined meeting of the subconmittees on Structural Engineering / Seismic Design and Piping / Metal Components, and ACRS consultants on Septenber 24, 1985. The proposed progran received uniformly f avorable comment from the ACRS members in attendance.

In addition, the progran has been discussed with members of the NRC legal staff. The progran has been revised to include suggestions made by the legal staff, who have stated that there is no conceptual legal difficulty with the proposed approach including any potential need for a schedular implementation progran.

Your early review of our proposed approach will be greatly appreciated.

If upon completion of your review you would like to discuss any progran details, we will be available at your convenience.

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United States Nuclear Regulatory Cmmission Mr. George W. Knighton, Chief Alternate Pipe Rupture Protection Program Page 3 .

Please note.that the enclosed docunent includes the request for withholding fran public disclosure in accordance with 10CFR 2.790. This application for witholding is being made by Duquesne Light Company on the behalf of Stone & Webster Engineering Corporation and-Robert L. Cloud Associates (affidavits attached).

Sincerely yours, d

J. . Carey Vice President JJS/uc cc: Mr. R. Bosnak Mr. H. R. Denton Mr. J. P. Knight Mr. B. K. Singh Mr. G. Walton

s e ROBERT L. CLOUD ASSOCI ATES. INC.

125 UNIVERSITY AVENUE 20 MAIN STREET SERMELEY. CALIFORNIA 94710 COTUIT. MASSACHUSETTS O2635 (415) 848 9296 (617) 428.3258 TELEX NO: 558 45e ,

October 7, 1985 P104-008 Beaver Valley 2 Project WHIPJET Program U.S. Nuclear Regulatory Commission Bethesda, MD This affidavit is submitted by Robert L. Cloud and Associates, Inc. (RLCA), for the WHIPJET program report dated October 2, 1985. RLCA is a Duquesne Light Company subcontractor for this project. The contents of the WHIPJET program are proprietary containing confidential technical subject matter. Public disclosure of the information contained in the WHIPJET report would cause substantial financial harm to RLCA because numerous man-hours spent in research and data gathering would be lost.

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/ JM2, .NY z 1 Y JAMRS S.M/LEUNG /

$16e-President /

Robert L. Cloud Associates, Inc.

STATE OF CALIFORNIA On this . . . ?.fh. . . . . . day of. . 0c$pN. . . . . .in the year . . 1985 ,

' as. ... . ... . ........... .. .. . .. .. .. . . . before me, COUNTY OF . . . . ALA# ERA. . . . . . . . . . . . . ARLENE . G . , NORRIS. , . . . . . . . . . . a Notary Public, State of California.

duly commissioned and sworn, personally appeared . . . . .. . .. . . . . .

. . . . JAMES. .S.. . M. . .LEUNG. , . . .. ..... . ..... .

personally known to me for proved to me on the basis of satisfactory evidence) to be OFylbAL S AL the person . . . . whose name . . . . . . .I.T . . .. ... ... . . . . ..

subscribed to this instrument, ard acknowledged that . . . he . . . executed it.

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G. MORRIS IN WITNESS WHEREOF I have hereunto set my hand and amred my omeial seal in the . . . . . .Sta te. Of. .CA M f4TnI A s. . . . .. . .. . . County of M

. . . . . . . . . . .CO UR CU . Of. 32 4MCd4. . . . . . . . . . . . . . on the date set forth above in this certificate.

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,e - , - e me ARLENE G. MOddIS Notary Public, State of Cabfornia

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My commission empires Cowdery's Form No. 32 - Acknowledpment to Notary Public -Individuals - tC.C. Sec.1189)-(Rev.1/83)

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AFFIDAVIT I, Philip A. Wild, being. duly sworn, depose and shy:

1. I am - a Senior Vice President of Stone & Webster Engineering Corporation (SWEC) and have the authority to review and protect the confidential commerical information sought to be withheld.

2. For the reasons listed below, the BVPS-?. WHIPJET PROGRAM contains information considered by SWEC to be confidential information containing trade secrets' of a type held in confidence by SWEC and not disclosed to the public.

a. The subject material consists of a program which is an alternative to the method for postulating and evaluating pipe ruptures as set forth in SRP 3.6.2. This program is a preventative program as opposed to a mitigative program.

b. SWEC is in the business of designing and constructing nuclear power plaats. This business is competitive and firms that engage in it compete on the basis of the nature of services that-they offer to clients. The subject material is one such service.

c. The subject material provides a method for consideration of postulated pipe ruptures and could be used by competitors in their designs.

d. The subject material was developed at considerable expense to SWEC, is of substantial value to SWEC in the conduct of its business, and a competitor would derive an unfair advantage in obt.aining the proprietary information contained therein.

Thus, the unrestricted disclosure of this material could have an adverse commercial impact on SWEC.

e. It is, accordingly, the customary practice of SWEC.and its competitors to treat such material as confidential commercial information.

f. To the best of my knowJedge and belief, 't he identified

. materials are not available from any public source and have l not been made available to third parties, except in confidence.

DATED: October 9, 1985 [c t' [h[/

Philip A.f4fild ~

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Senior Vice President Stone & Webster Engineering Corporation 1758-1224106-84

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COMMONWEALTH OF MASSACHUSETTS i l

October 9, 1985 Suffolk, ss. .

Subscribed and sworn to before me on the 9th day of October, 1985.

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Notary Public My Commission expires: BLANCH bi #0b7 ^

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