ML20140A446
| ML20140A446 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 03/12/1986 |
| From: | Goldberg J HOUSTON LIGHTING & POWER CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19276D353 | List: |
| References | |
| CON-#186-469 OL, ST-HL-AE-1617, NUDOCS 8603200210 | |
| Download: ML20140A446 (6) | |
Text
The Light COIIIpMf flousum 1.ighting & Power I!O. Box 170011ouston, Texas 77001 (713) 228-9211
'SfN-Ahl File No.: G9.10 Mr. Harold Denton, Director Office of Nuclear Reactor Regulation Nuclear Regulatory Commission Washington, DC 20555 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Alternative Pipe Break Criteria For Pressurizer Surge Line
Reference:
- 1) Letter from J. H. Goldberg (HL&P) to H. R. Denton (NRC) dated September 28, 1983 (ST-HL-AE-1010)
- 2) Letter from J. H. Goldberg (HL&P) to H. R. Denton (NRC) dated July 17, 1984 (ST-HL-AE-1096)
- 3) Letter from J. H. Goldberg (HL&P) to H. R. Denton (NRC) dated August 19, 1985 (ST-HL-AE-1326)
Dear Mr. Denton:
On August 19, 1985, Houston Lighting & Power Company (HL&P), by way of reference (3) above, requested a schedular exemption to the requirements of 10CFR50, Appendix A, General Design Criteria (GDC)-4 for the treatment of main reactor coolant loop pipe breaks inside the containment.
This schedular exemption was requested to cover the period until startup following the second refueling outage and eliminate the need to install the associated pipe whip restraints and jet impingement shields for the RCS main loop and cross-over piping and to eliminate the need to design for the dynamic effects associated with these breaks, including jet impingement and compartment pressurization.
HL&P is continuing to pursue the application of alternative pipe break design bases to other piping systems.
In accordance with 10CFR50.12(a), HL&P hereby applies for an exemption to the requirements of 10CFR50, Appendix A, GDC-4 for the treatment of pressurizer surge line pipe breaks.
This exemption would eliminate the need to install the associated pipe whip restraints and jet impingement shields and to eliminate the need to design for the dynamic effects associated with these breaks. These dynamic effects are specifically defined as the effects of missiles, pipe whipping, subcompartment pressuri-zation, and fluid jets. Granting our request (1) would eliminate the need to postulate longitudinal and circumferential pipe breaks in the pressurizer surge line piping; and 2) eliminate the requirement to analyze and design for U
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ST-HL-AE-1617 File No.: G9.10 Houston Lighting & Power Company Page 2 the following dynamic effects of these breaks: jet impingement, blowdown loads, pipe whip, reactor cavity pressurization, asymmetric pressurization transients (USI A-2), subcompartment pressurization transients, and load combination assumptions. This exemption request does not affect the containment pressure boundary, the emergency core cooling system, or environmental qualification design bases. Pursuant to 10CFR50.12(a), HL&P believes the requested exemption "will not endanger life or property or the common defense and security and is otherwise in the public interest".
Accordingly, HL&P as Project Manager for STP, acting for itself and for the City of San Antonio (acting by and through the City Public Service Board of San Antonio), Central Power and Light Company, and the City of Austin, Texas, hereby requests that Construction Permit (CP) Nos. CPPR-128 and CPPR-129 be amended to reflect the above stated partial exemption to GDC-4.
Enclosed in accordance with 10CFR Section 170.12 is a check in the amount of
$300 in payment of the application fees associated with the request for amendments of the two construction permits.
In support of this request, HL&P is enclosing a report, WCAP-10489,
" Technical Bases for Eliminating Pressurizer Surge Line Ruptures as the Structural Design Basis for the South Texas Project" as Enclosure A.
Enclosure C contains additional information in support of Enclosure A.
Because of the proprietary nature of these documents, Enclosures A and C have-been provided only to the addressee, to Mr. R. D. Martin, and to Mr. N. P.
Kadambi of the NRC. Non-proprietary versions have been included as Enclosures B and D and have been provided to others on the attached distribution list.
This report and the additional information provide technical justification for the elimination of pressurizer surge line breaks based on fracture mechanics analysis. The application of this fracture mechanics technology has demonstrated that small flaws or leakage cracks will remain stable and will be detected either by in-service inspection or by leakage monitoring systems long before such flaws can grow to critical sizes which otherwise could lead to large break areas such as a double ended rupture of the surge line.
A safety balance assessment is submitted as Enclosure E.
As demonstrated in this safety balance assessment, the strict application of the definition of a loss of coolant accident (LOCA) in Appendix A to 10CFR Part 50, without applying advanced fracture mechanics technology to large diameter, thick walled piping, such as the pressurizer surge line, imposes a penalty in terms of both cost and occupational radiation exposure. For the STP, a nominal occupational radiation exposure savings in excess of 24 man-rem can be achieved over the 40 year life of both units as a result of not installing the protective devices (pipe whip restraints and jet impingement barriers) currently employed in the STP design to mitigate the dynamic effects I
associated with postulated breaks in the pressurizer surge line. As shown in Ll/NRC/ds
ST-HL-AE-1617 Houston Lighting & Power Company Pa the same analysis, this real reduction in occupational radiation exposure is to be contrasted with e 0.3 man-rem calculated increase in radiation exposure to the general public in the unlikely event of a pipe rupture.
The pressurizer surge line currently contains postulated pipe breaks at two terminal cads, two fittings and at the lcng radius bend. Pipe whip restraints have been fabricated for both units and have been partially installed in Unit 1.
Jet impingement barriers have not been fabricated.
The cost savings associated with not completing Unit 1 restraint installation, not installing the Unit 2 restraints, and with not fabricating or installing jet impingement barriers in either unit is estimated to be in excess of
$400,000.
In order to achieve the benefits of substantially reduced occupational radiation exposure and to avoid remaining installation cost for both units, we request your prompt and favorable action.
Because Enclosures A and C contain information proprietary to Westinghouse Electric Corporation, the attached affidavits signed by Westinghouse management set forth the basis on which the information may be withheld from public disclosure by the NRC in accordance with the requirements of 10CFR2.790(b)(1). These affidavits address with specificity the considerations of 10CFR2.790(b)(4). Correspondence with respect to the proprietary aspects of the affidavit and Application for Withholding of Enclosure A and C should reference CAW-84-12 and CAW-84-76 respectively and should be addressed to R. A. Wisemann, Manager Regulatory and Legislature Affairs, Westinghouse Electric Corporation, P. O. Box 355, Pittsburgh, Pennsylvania 15230.
It is noted for your information that this program will not affect the following:
- Emergency Core Cooling System (ECCS) design bases
- Containment design bases
- Equipment qualification bases (overall design conditions)
- Engineered Safety Features System response
- Design of RCS heavy component supports If you should have any questions on this matter, please contact Mr. M. E. Powell at (713) 993-1328.
Very truly yours, i
J. H. Goldberg Group Vice President, Nuclear MEP/yd Ll/NRC/ds
ST-HL-AE-1617 Fils No.: G9.10 Page 4 Houston Lighting & Power Company Attachments: A)
WCAF-10489, Technical Bases for Eliminating Pressurizer Surge Line Ruptures last the Structural Design Basis for South Texas Units 1 and 2, prepared by S. A. Swamy, C. Y. Yang, A. D. Sane, Y. S. Lee, dated February, 1984 (Proprietary)
B)
WCAP-10490, Technical bases for Eliminating Pressurizer Surge Line Ruptures as the Structural Design Basis for South Texas Units 1 and 2, prepared by S. A. Swamy, C. Y. Yang, A. D. Sane, Y. S. Lee, dated February, 1984 (Non-Proprietary)
C)
Additional information on the Report Titled, " Technical Bases for Elimination Pressurizer Surge Line Ruptures as the Structural Design Basis for South Texas Units 1 and 2, "WCAP-10489, February, 1984 (Proprietary)
D)
Additional information on the Report Titled, " Technical Bases for Eliminating Pressurizer Surge Line Ruptures as the Structural Design Basis for South Texas Units 1 and 2," WCAP-10489, February, 1984 (Non-Proprietary)
E)
Safety Balance for Elimination of Pressurizer Surge Line Break Protective Devices for South Texas Projects Unit 1 and 2 i
L1/NRC/ds
ST-HL-AE-1617 Houston Lighting 8c Power Company File No.: G9.10 Page 5 cc:
Hugh L. Thompson, Jr., Director Brian E. Berwick, Esquire Division of PWR Licensing - A Assistant Attorney General for Office of Nuclear Reactor Regulation the State of Texas U.S. Nuclear Regulatory Commission P.O. Box 12548, Capitol Station Washington, DC 20555 Austin, TX 78711
(*) Robert D. Martin Lanny A. Sinkin Regional Administrator, Region IV Christic Institute Nuclear Regulatory. Commission 1324 North Capitol Street 611 Ryan Plaza Drive, Suite 1000 Washington, D.C.
20002 Arlington, TX 76011 Oreste R. Pirfo, Esquire
(*)N. Prasad Kadambi, Project Manager Hearing Attorney U.S. Nuclear Regulatory Commission Office of the Executive Legal Director 7920 Norfolk Avenue U.S. Nuclear Regulatory Commission Bethesda, MD 20814 Washington, DC 20555 Claude E. Johnson Charles Bechhoefer, Esquire Senior Resident Inspector /STP Chairman, Atomic Safety &
.c/o U.S. Nuclear Regulatory Licensing Board Commission U.S. Nuclear Regulatory Commission P.O. Box 910 Washington, DC 20555 Bay City, TX 77414 Dr. James C. Lamb, III M.D. Schwarz, Jr., Esquire 313 Woodhaven Road Baker & Botts Chapel Hill, NC 27514 One Shell Plaza Houston, TX 77002 Judge Frederick J. Shon Atomic Safety and Licensing Board J.R. Newman, Esquire U.S. Nuclear Regulatory Commission Newman & Holtzinger, P.C.
Washington, DC 20555 1615 L Street, N.W.
Washington, DC 20036 Mr. Ray Goldstein, Esquire 1001 Vaughn Building Director, Office of Inspection 807 Brazos and Enforcement Austin, TX 78701 U.S. Nuclear Regulatory Commission Washington, DC 20555 Citizens for Equitable Utilities, Inc.
c/o Ms. Peggy Buchorn T.V. Shockley/R.L. Range Route 1, Box 1684 Central Power & Light Company Brazoria, TX 77422 P.O. Box 2121 Corpus Christi, TX 78403
(*) Docketing & Service Section Office of the Secretary H.L. Peterson/G. Pokorny U.S. Nuclear Regulatory Commission City of Austin Washington, DC 20555 P.O. Box 1088 (3 Copies)
Austin, TX 78767 Advisory Committee on Reactor Safeguards J.B. Poston/A. vonRosenberg U.S. Nuclear Regulatory Commission City Public Service Board 1717 H Street P.O. Box 1771 Washington, DC 20555 San Antonio, TX 78296 Revised 12/2/85
(*) Include attachments A&C, all others without attachments A&C Ll/NRC/ds
r-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter 5
5
' Houston Lighting & Power.
5 Docket Nos. 50-498 Company, et al.,
5 9
South Texas Project 5
Units 1 and 2 AFFIDAVIT J. H. Goldberg being first duly sworn, deposes and says:
That he is Group Vice President, Nuclear, of HOUSTON LIGHTING & POWER COMPANY, Project Manager of the South Texas Project and an Applicant herein; that the foregoing request for amendments of Construction Permits Nos. CPPR-128 and CPPR-129, to permit exemption from the requirements of General Criteria 4 (Appendix A to 10CFR50) as they relate to the dynamic effects of postulated circumferiential and longitudinal breaks in the pressurizer surge lines at the South Texas Project has been prepared under his supervision and direction; that he knows the contents thereof; and that to the best of his knowledge and belief said request and the facts contained therein are true and correct.
DATED:
This / 2-day of 31*/,1986.
/ J Signed:
_A J. H. Goldberg V Group Vice President, Nuclear STATE OF TEXAS COUNTY OF HARRIS Subscribed and sworn to before me, a Notary Public in and for Harris County, Texas this < 211 day of wtuv, 1986.
N bunuls Sn$bQ yV Notary Public in and for the State of Texas My commission expires:
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