ML20141G493

Forwards NRC Re Alternate Pipe Rupture Protection Program (Whipjet) & Application of leak-before-break Technology to balance-of-plant Piping Sys

ML20141G493
Person / Time
Site:	Seabrook
Issue date:	04/17/1986
From:	Noonan V Office of Nuclear Reactor Regulation
To:	Harrison R PUBLIC SERVICE CO. OF NEW HAMPSHIRE
References
NUDOCS 8604230411
Download: ML20141G493 (3)

Text

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-Docket Nos.: 50-443 and 50-444- APR IT Y

'. Mr. Robert J. Harrison

- President & Chief Executive Officer Public Service Company of New Hampshire P.O. Box 330

^ Manchester, NH~ 03105

SUBJECT:

ALTERNATE PIPE RUPTURE PROTECTION PROGRAM (WHIPJET)

Enclosed -is a staff letter to Duquesne Light Company that may. be of interest ,

and use to'you. The enclosed letter pertains to Beaver Valley Power Station

, - Unit'2,.and the application of leak-before-break technology to balance of

' plant piping systems.

Questions or additional information regarding this matter should be directed

.to the Seabrook Project Manager, Mr. V. Nerses, (301-492-8535).

Sincerely, N

Vincent S. Noonan, Director PWR Project Directorate No. 5 Division of PWR Licensing-A

Enclosure:

-As stated cc: See next page

Distribution:

155Ef7TTes~

- C.E. Rossi NSIC JMilhoan JPartlow Hayes ACRS (16) JLee NRC PDR EJordan LPDR PRC System PD#5 Rdg. Files VNerses BGrimes OELD s:js ha

-04/M /86 04 /7 / 6 0FFICIAL RECORD COPY 8604230411 860417 PDR ADOCK 05000443 A PDR -

Mr. Robert J. Harrison

, Public Service Company of New Hampshire Seabrook Nuclear Power Station

!' cc:

! Thomas Dignan, Esq. E. Tupper Kinder, Esq.

John A. Ritscher, Esq. G. Dana Bisbee, Esq.

Ropes and Gray Assistant Attorney General l

225 Franklin Street Office of Attorney General Boston, Massachusetts 02110 208 State Hosue Annex Concord, New Hampshire 03301 Mr. Bruce B. Beckley, Project Manager Public Service Company of New Hampshire Resident Inspector Post Office Box 330 Seabrook Nuclear Power Station Manchester, New Hampshire 03105 c/o US Nuclear Repulatory Commission l Post Office Box 700 Dr. Mauray Tye, President Seabrook, New Hampshire 03874 Sun Valley Association t

209 Sumer Street Mr. John DeVincentis, Director Haverhill, Massachusetts 01839 Engineering and t.icensing Yankee Atomic Electric Company Robert A. Backus, Esq. 1671 Worchester Road O'Neil, Backus and Spielman Framingham, Massachusetts 01701 1161.owell Street Manchester, New Hampshire 03105 Mr. A. M. Ebner, Project Manager United Engineers & Constructors William S. Jordan, III 30 South 17th Street Diane Curran Post Office Box 8223 Harmon, Weiss & Jordan Philadelphia, Pennsylvania 19101 20001 S Street, NW Suite 430 Washington, D.C. 20009 Mr. Philip Ahrens, Esq.

Assistant Attorney General State House, Station #6 Augusta, Maine 04333 Jo Ann Shotwell, Esq.

Office of the Assistant Attorney General Environmental Protection Division Mr. Warren Hall One Ashburton Place Public Service Company of Boston, Massachusetts 02108 New Hampshire Post Office Box 330 D. Pierre G. Cameron, Jr. , Esq.

Seabrook, New Hampshire 03874 General Counsel Public Service Company of New Hampshire l Seacoast Anti-Pollution I.eague Post Office Box 330 l Ms. Jane Doughty Manchester, New Hampshire 03105 i 5 Market Street Portsmouth, New Hampshire 03801 Regional Administrator, Region I l U.S. Nuclear Regulatory Commission l Mr. Diana P. Randall 631 Park Avenue '

70 Collins Street King of Prussia, Pennsylvania 19406 Seabrook, New Hampshire 03874 l

Richard Hampe, Esq.

i New Hampshire Civil Defense Agency 107 Pleasant Street Concord, New Hampshire 03301 l

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-Public Service Company of ~ Seabrook Nuclear Power Station New Fampshire CC:

Mr. Calvin A. Canney, City Manager Mr. Alfred V. Sargent.

City Hall .

Chairman 126 Daniel Street Board of Selectmen Portsmouth, New Fampshire 03801 Town of Salisbury, MA 01950 Ms. Letty Fett Senator Gordon J. Humphrey Town of Brentwood ATTN: Tom Burack RFD Dalton Road U.S. Senate

, Brentwood, New Hampshire 03833 Washington, D.C. 20510 Ms. Roberta C. Pevear Mr. Owen B. Durgin; Chairman Town of Hampton Falls, New Hampshire Durham Board of Selectmen Drinkwater Road Town of Durham Hampton Falls, New Hampshire 03844 Durham, New Hampshire 03824-Ms. Sandra Gavutis Charles Cross, Esq.

Town of Kensington, New Hampshire Shaines, dardrigan and RDF 1 McEaschern East Kingston, New Hampshire 03827 25 Maplewood Avenue i

Post Office Box 366 Portsmouth, New Hampshire 03801 Chairman, Board of Selectmen RFD 2 South Fampton, New Hampshire 03827 Mr. Guy Chichester, Chaiman Rye Nuclear Intervention Mr. Angie Machiros, Chairman Committee Board of Selectmen c/o Rye Town Hall for the Town of Newbury 10 Central Road Newbury, Massachusetts 01950 Rye, New Hampshire 03870 Ms. Cashman, Chairman Jane Spector Board of Selectmen Federal Energy Regulatory Town of Amesbury Commission Town Hall 825 North Capital Street, NE Amesbury, Massachusetts 01913 Room 8105 Washington, D. C. 20426 Ponorable Peter J. Matthews Mayor, City of Newburyport Mr. R. Sweeney Office of the Mayor New Hampshire Yankee Division City Fall Public Service of New Hampshire Newburyport, Massachusetts 01950 Company 7910 Woodmont Avenue Mr. Dori E. Chick, Town Manager Bethesda, Maryland 20814 Town of xeter 10 Front Street Mr. William 8. Derrickson Exeter, New Hampshire 03823 Senior Vice President Public Service Company of New Hampshire Post Office Box 700, Route 1 Seabrook, New Hampshire 03874

' W. } UNITED 3TATES ENCLOSURE

f. NUCLEAR REGULATORY COMMISSION -

, ,. i p, f CASHINGTON, D. C. 20555 k*..**,/

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p March 3, 1986

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- ' m Docket No.: 50-412  ;

m Mr. J. J. Carey, Vice President j Duquesne Light Company j

, Nuclear Group -

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P. O. Box 4 . 3 Shippingport, PA 15077 3 r 'l

Dear Mr. Carey:

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SUBJECT:

BEAVER VALLEY POWER STATION - UNIT NO. 2 ALTERNATE PIPE RUPTURE ~

7 PROTECTIONPROGRAM(WHIPJET)

The NRC staff has perfomed a preliminary review of the proposed WHIPJET 2 program submitted via Duquesne Light Company letters of September 6,1985, ,

and October 10, 1985. Although we have specific conments that should be -

discussed in a technical meeting, we believe that the general approach has  :

3 merit. . -

1 The NRC Piping Review Comittee reports, particularly NUREG-1061. Volume 3,

" 1 provide general guidance and criteria for the application of  ?

leak-before-break (LBB) technology to reactor coolant loop piping. However, =

specific acceptance criteria for balance of plant (BOP) piping systems still i

• need to be fomulated. For example, criteria regarding the magnitude of -

fluid leakage discharged through a flaw relative to the capability of 3 i

" leakage detection will have to be developed for piping outside containment. I The matter of criteria development has been discussed with industry

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representatives on a number of occasions. In particular, we have encouraged 3 industry to proceed expeditiously in the development of applicable standards 1 via ANS-58.2-1980 and various ASME comittees and task groups. NRC i i representatives in these organizations will participate in this effort. We

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are willing to work with Duquesne Light on a mutually acceptable schedule to I review specific questions as they arise. We expect that LBB technology will i

evolve over the next few years as more pipe tests are conducted and various j

, analytical procedures are refined. In view of the above, we suggest that Duquesne Light keep the NRC staff informed periodically, perhaps by a quarterly progress report and/or meeting, to avoid last minute differences l

" j of opinion that may affect the licensing schedule.

g Section 5.1 of NUREG-1061, Volume 3, indicates that the LBB approach should #

not be applied to high energy fluid system piping susceptible to failure -

from the effects of corrosion, water hammer, or fatigue. However, it may be i s difficult to make a clear cut determination regarding these limitations for

= certain piping systems. Based on our review of the Duquesne submittals, your thinking in this area appears to reflect the NUREG-1061 guidance; however, the specific systems affected still need to be agreed upon.

We expect that initially the program will deal with demonstrating which

" piping systems can be included in the WHIPJET program beginning with those j systems where the economic advantage is greatest.

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Potentially controversial systens should either be excluded fros the WHIPJET program or addressed at a later stage to avoid delays in the overall program.

The WHIPJET program submitted by Duquesne Light is marked " proprietary." The -

NRC staff recognizes that certain aspects of the program can bejustified as sensitive or proprietary information. However, eventually the staff will "

have to prepare a nan-proprietary safety evaluation. We recomend that, to the extent possible, subsequent Duquesne Light submittals be kept non-proprietary with any proprietary information provided in separate appendices or reports. -

Finally, you should be advised that a technical exemption under 10 CFR 50.12(a) i could be necessary to implement the results of the WHIPJET evaluation if 9 GDC-4 is not amended to allow application of LBB beyond the prinary coolant -

loop. In addition, for any balance-of-plant pipe restraints that do not meet e the criteria for a technical exemption, a schedular exemption would be =

necessary to allow plant operation before the requirements of GDC 4 are met.

In this regard, anticipated reliance on the results of an evaluation which -

would provide the justification for a technical exemption from the appli-cable regulation may not constitute the " good faith efforts to comply with the regulation" required to meet the criterion for a schedular exemption under 10 CFR 50.12(a)(2)(v). However, because of the generic value of the -

WHIPJET evaluation, you may qualify for a schedular exemption under 10 CFR 50.12(a)(2)(vi). This criterion provides for the issuance of an exemption where it is shown that there is present "any other material circumstance not .

considered when the regulation was adopted for which it is in the public a interest to grant an exemption." Any staff finding on this criterion must be -

reviewed by the Commission. -

If you need clarification a have any questions, please cell your project  :

manager, Mr. P. Tam, at anytime.

Sincerely, 5 Thomas M. Novak, Acting Director i Division of PWR Licensing-A -

Office of Nuclear Reactor Regulation d

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