ML20204J443

Responds to & Requests That Formal NRC Review of EPRI Hydrogen Water Chemistry Installation Guidelines Be Expanded to Include Liquid Oxygen & Compressed Gaseous Hydrogen Storage Options

ML20204J443
Person / Time
Site:	Pilgrim
Issue date:	06/12/1986
From:	Neils G BWR OWNERS GROUP, NORTHERN STATES POWER CO.
To:	Bernero R Office of Nuclear Reactor Regulation
Shared Package
ML20204J386	List: ML20204J380 ML20204J401 ML20204J417 ML20204J443 ML20204J494 ML20204J531 ML20204J537 ML20204J557 ML20204J579 ML20204J599 ML20204K042 ML20206Q053 ML20207A530 ML20207A535 ML20207A686 ML20207A766
References
FOIA-88-198 NUDOCS 8810250136
Download: ML20204J443 (2)

Text

_ _ _ _ _ _ - _ _ _ _ _ .

.' l Northem States Power Company 414 Neonet Mag M nme8DObs MMeleta $$401 Tevpnone (6121330 5500 June 12,1986 W4L u m,y s '

Mr. Robert M. Bernero, Director , , W . ,y <

Oivision of BWR Licensing e g er ,4.)/

Nuclear Reactor Regulation . . -

M & .....

U.S. Nuclear Regulatory Commission Washington, DC 20555 ,

Subject:

NRC Review of EPRI Hydrogen Water Chemistry Installation Guidelines Referent.e: 1) Letter, Robert M. Bernero to G. H. Neils, dated February 7, 1986

2) "Guidelines for Permanent BWR Hydrogen Water Chemistry -

Installations", EPRI NP-4500-SR-LO, March 1986

3) Letter, F. Witt to L. G. Hulman, "Meeting with BWR Owners Group Regarding Guidelines for Pemanent BWR Hydrogen Water Chemistry Installations, A9ril 16,1986",

May 1, 1986

4) letter, L. G. Hulman to G. H. Neils, "Guidelines for Pemanent BWR Hydrogen Water Chemistry Installations -

Request for Additional Infomation", dated May 8,1986

Dear Mr. Bernero:

This letter is a response to your Reference 1 letter and requests that the formal NRC review of the EPRI Hydrogen Water Chemistry Installation (HWC)

Guidelines (Reference 2) be expanded to include the liquid oxygen and compressed gaseous hydrogen storage options.

On April 16, 1986 the Hydrogen Water Chemistry Installation Guidelines Subcomittee of the BWR 0=ners' Group for IGSCC Research met with your staff to discuss the technical and licensing issues associated with a review of Reference 2. As noted in Reference 3, the original staff approach was to officially review only the liquid hydrogen storage option and issue a Safety Evaluation Report (SER). The other hydrogen and oxygen supply options would be infomally reviewed with coments provided to improve the guidelines.

At the April 16 meeting, the Subcomittee requested that the staff's formal review and $ER include all hydrogen and oxygen storage options (i.e., liquid hydrogen, liquid nygen and gaseous hydrogen). The electrolytic option generater +;rogen and oxygen as needed and is not considered a stcrage opticn. D>..s. a formal review of the electrolytic option is not requested.

9810250136 000914 hNS 4 -198 PDR

,  ? Robert M. Bernero Page 2 June 12, 1986 On May 22 the Subconmittee again met with the NRC staff to provide preliminary responses to the NRC Request for Additional Information (Reference 4). Formal responses to these questions will be submitted in '

the near future in the form of revisions or additions to Reference 2. To help expedite the review, the subcommittee would be pleased to meet with the staff to address any additional questions that may arise as a consequence of the expanded scope.

Regards, G. H. g is, Chairman Regulatory Advisory Committee BWR Owners Group for IGSCC Research 3903SM6A cc: L. G. Hulman F. J. Witt

! I l

1 I

l 4

i I

\

b TDf

/ 'c, UNITED $T ATES #1 NUCLE AR REGULATORY COMMISSION I T TMW

!" ; w ,e

] j i wassmotow. o. c. 20sss

• \ v...../

FEB 0 71986 Mr. G. H. Neils Chairman, Regulatory Advisory Comittee BWR Owner's Group 11 for Intergranular Stress Corrosion Crackino Research 414 Nicollet Hall Minneapolis, Minnesota 55401

DearMr.Neiks:

Wa have received the draf t of "Guidelines for Permanent BWR Hydrogen Water Cremistry Installations", you sent to Mr. Harold Denton on October 12, 1985 fur s'taf f review. The staff has supplied informal coments on this Draft wnich were given to the Gwner's Group on October 9, 1985. On February 5, -

j 158$, we received the Final Guide and intend to provide coments on its content. However, the staff will not conouct a fomal review of the Guide since its intended applications are to support plant specific. modifications to be performed assuming there are no unreviewed safety questions under the provisions of 10 CFR 50.59. Any specific modifications performed at a facility under the provisions of 10 CFR 50.59, including Hydrogen Water Chemistry modifications would be subject to the regular inspection pronss and 10 CFR 50.59 review.

The following coments are relevant to potential plant specific Hydrogen Chemistry Modifications. Many aspects of potential Hydrogen Water Chamistry Modifications appear to be of the type of mcdifications that will be able i to be carried out without license amendment under the criteria of 10 CFR 50.59. ,

Suitable comprehensive evaluation of whether or not the modifications constitutes an unreviewed safety Question for the specific facility should be included as a part of the Safety Evaluation supporting the modification.

Some aspects of potential hydrogen water chemistry modifications, in particular the permanent installation storage and use of relatively large quantities of liquid hydrogen on site at a specific facility, appear to raise the concern of potentially new and d'fferent accidents from those i prev'iously consT 4 rvd and eialuated as a p~ art of the (~t ^1 Tty licensing

~

process.~ The ceWHnina't'idi~oGfieTher or not the ha: aids associatedivith the pote'n tial explosion and fire hazards from the storage and use of relatively large quantities of liquid hydrogen and/or oxygen at a specific facility require careful consideration by a licensee when reaching a determination as to whether a prooosed mocification involves any of the three criteria for

- "anunreviewedsafetyquestion"defir. edin 10CFR50.59(a)(2).

c t

W*

e E

I ,

j l t

FE8 0 7 W Mr. G. H. Nfils 2-4 Mr. Robert A. Hemann of my staff will remain as the staff contact for this l

work and will be available to work with the Owner's Group on this subjact.

}' .c 1W,.,_

' Robert M. Bernero, Director j Division of BWR Licensing i

i l

l l ,

4 1

1 1 \

i I

s

• k i t I  ;

1 O i

I i-4 3 ,

I 1

I l l

)

i j - .

4 4