ML20214A142
| ML20214A142 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 11/14/1986 |
| From: | Wisenburg M HOUSTON LIGHTING & POWER CO. |
| To: | Noonan V Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19292G273 | List: |
| References | |
| RTR-NUREG-1061 ST-HL-AE-1784, NUDOCS 8611190263 | |
| Download: ML20214A142 (6) | |
Text
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,g The Light NE Ef flouston Lighting & Power EO. Ilox 1700 llouston.'lexas, <001 (713) 228-9211 November 14, 1986 STeHL-AE-1784 File No.: G9.10 Mr. Vincent S. Noonan, Project Director PWR Project Directorate #5 U. S. 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 - Accumulator Line
References:
(1) HL&P letter to NRC, J. H. Goldberg to H. R. Denton, March 12, 1986, ST-HL-AE-1617 (2) NRC letter to HL&P, N. P. Kadambi to J. H. Goldberg, July 10, 1986, ST-AE-HL-90935 (3) HIAP letter to NRC, M. R. Wisenburg to V. S. Noonan, September 15, 1986, ST-HL-AE-1737 (4) HiAP letter to NRC, J. H. Goldberg, to H. R. Denton, June 10, 1986, ST-HL-AE-1681
Dear Mr. Noonan:
By letter dated March 12, 1986 (reference 1), Houston Lighting & Power Company (HL&P) provided the technical basis for the elimination of postulated pipe ruptures in the pressurizer surge line, and requested an exemption to the requirements of 10CFR50, Appendix A GDC-4 for treatment of postulated surge line breaks.
The purpose of this submittal is to amend the March 12, 1986 exemption request to include postulated breaks in a portion of the cold leg accumulator injection piping.
The NRC staff reviewed the information contained in our March 12, 1986 submittal and submitted a request for additional information (reference 2).
In response to the NRC request for additional information, HL&P provided the technical information in reference 3.
A meeting was held with the NRC on October 1, 1986 to review the reference 3 information and to discuss the reference 4 submf ttal related to elimination of postulated pipe rupture in balance of plant piping. At that meeting, the NRC staff had additional questions which were addressed in a subsequent meeting which was held with the NRC on October 15, 1986.
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During both of the October, 1986 meetings, HL&P and Westinghouse provided presentations and handout material relative to Leak-Before-Break on the STP surge line and accumulator line. These presentations demonstrated that the criteria in NUREG 1061, Volume 3, Section 5.2 are met for the surge line and that portion of the accumulator line between the reactor coolant loop connection and the second check valve.
Based upon demonstrating compliance with the NUREG 1061 criteria and documentation specific to the accumulator line being provided by January 7, 1987, HL&P hereby amends its exemption request of March 12, 1986 to include the portion of the accumulator line between the reactor coolant loop connection and the second check valve and the connecting 10 inch and 8 inch lines from the accumulator line to the first valve as shown on Figure 1 of Attachment 1.
This request is consistent with the NRC Staff Piping Review Committee's recommendations in NUREG 1061, Volume 3, and those programs which formed the bases for schedular exemptions authorized for numerous plants for reactor coolant system main loop piping. HL&P considers the application of the leak-before-break technology to be a more effective and reasonable approach to ensure adequate pipe break protection than the installation of pipe break restraints and jet shields.
Elimination of these postulated accumulator line breaks would have the following effects on STP design for Units 1 and 2.
o Eliminate the need.to install associated pipe break restraints and jet impingement shields, o
Eliminate the need to consider associated dynamic effects and loading conditions including jet impingement loads, subcompartment pressurization, blowdown loads in the lines, attached piping and adjacent components, and component supports.
This program will not affect the following:
o Emergency Core Cooling System (ECCS) design bases o
Containment design bases o
Equipment qualification design bases o
Engineered Safety Features System response o
Design margin of RCS heavy component supports This exemption for Units 1 and 2 would eliminate the need to install the associated pipe whip restraints and jet impingement shields and to eliminate the need to design for dynamic effects associated with breaks. The dynamic effects associated with the accumulator line breaks and connecting line breaks are specifically defined as the effects of missiles, pipe whipping, sub-compartment pressurization, and fluid jets. Approval of this request would (1) eliminate the need to postulate longitudinal and circumferential pipe breaks in the accumulator line piping and connecting 10 inch and 8 inch lines L1/NRC/mb
ST-HL-AE-1784 Houston Lighting Sc Power Company File No.: G9.10 Page 3 and (2) eliminate the requirement to analyze and design for the following dynamic effects of these breaks: jet impingement, blowdown loads, pipe whip, reactor cavity pressurization, 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), HIAP believes the requested exemption "will not endanger life or property or the common defense and security and is otherwise in the public interest."
Provided as Attachment 1 to this letter is one copy of the October 15, 1986 Meeting Presentation on.the accumulator line demonstrating compliance with the NUREG 1061 criteria, which has been designated as proprietary. to this letter is one copy of the October 15, 1986 Meeting Presentation on the accumulator line, which has been designated as non-proprietary.
Permission was granted in a letter from E. P. Rahe, Jr.
(Westinghouse) to Mr. D. G. Eisenhut (USNRC) dated November 15, 1984 for information of this type to be included in the NRC's Safety Evaluation aupporting the published conclusions.
This specific information and detailed supporting technical bases will be documented in a specific Westinghouse Topical Report (WCAP) related to Fracture Mechanics Analyses of STP Accumulator Piping attached to the RCS. This WCAP will be provided by January 7, 1987.
Because Attachment 1 contains information proprietary to Westinghouse Electric Corporation, the attached affidavit signed by Westinghouse management sets 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). This affidavit addresses with specificity the considerations of 10CFR2.790(b)(4). Correspondence with respect to the proprietary aspects of the affidavit and Application for Withholding of
- l. should reference CAW-86-100 and should be addressed to R. A.
Wiesemann, Manager Regulatory and Legislature Affairs, Westinghouse Electric Corporation, P. O. Box 355, Pittsburgh, Pennsylvania 15230.
If you should have any questions on this matter, please contact Mr. M. E. Powell at (713) 993-1328.
Very tr you
- 4. R. W:senburg Deputy oject Mana er ABP/yd Ll/NRC/mb l
ST-HL-AE-1784 Houston Lighting & Power Company File No.: G9.10 Page 4 Attachments:
(1)
" Presentation and Handout Material Relative to LBB Calculations for South Texas Project 12-inch Diameter Accumulator Line", Dated October 15, 1986 Westinghouse Proprietary Class 2.
(Also enclosed is a Westinghouse Authorization Letter, (CAW-86-100), Proprietary Information Notice, and accompanying Affidavit)
(2)
" Presentation and Handout Material Relative to LBB Calculation for South Texas Project 12-inch Diameter Accumulator Line" Dated October 15, 1986 Westinghouse Non-proprietary Class 3.
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Houston Lighting Jic Power Company ST-HL-AE-1784 File No.: G9.10 Page 5 cc:
Hugh L. Thompson, Jr., Director T.V. Shockley/R.L. Range Division of PWR Licensing - A Central Power & Light Company Office of Nuclear Reactor Regulation P.O. Box 2121 U.S. Nuclear Regulatory Commission Corpus Christi, TX 78403 Washington, DC 20555 O. Backus/J. E. Malaski Robert D. Martin City of Austin Regional Administrator, Region IV P.O. Box 1088 Nuclear Regulatory Commission Austin, TX 78767 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 J. B. Poston/A. vonRosenberg City Public Service Board N. Prasad Kadambi, Project Manager P.O. Box 1771 U.S. Nuclear Regulatory Commission San Antonio, TX 78296 7920 Norfolk Avenue Bethesda, MD 20814 Brian E. Berwick, Esquire Assistant Attorney General for Dan R. Carpenter the State of Texas Senior Resident Inspector / Operations P.O. Box 12548, Capitol Station c/o U.S. Nuclear Regulatory Austin, TX 78711 Commission P.O. Box 910 Lanny A. Sinkin Bay City, TX 77414 Christic Institute 1324 North Capitol Street Claude E. Johnson Washington, D.C.
20002 Senior Resident Inspector /STP c/o U.S. Nuclear Regulatory Oreste R. Pirfo, Esquiro Commission Hearing Attorney P.O. Box 910 Office of the Executive Legal Director Bay City, TX 77414 U.S. Nuclear Regulatory Commission Washington, DC 20555 M.D. Schwarz, Jr., Esquire j
Baker & Botts Citizens for Equitable Utilities, Inc.
One Shell Plaza c/o Ms. Peggy Buchorn l
Houston, TX 77002 Route 1, Box 1684 Brazoria, TX 77422 J.R. Newman, Esquire l
Newman & Holtzinger, P.C.
Docketing & Service Section 1615 L Street, N.W.
Office of the Secretary l
Washington, DC 20036 U.S. Nuclear Regulatory Commission Washington, DC 20555 Director, Office of Inspection (3 Copies) and Enforcement U.S. Nuclear Regulatory Commission Advisory Committee on Reactor Safeguards Washington, DC 20555 U.S. Nuclear Regulatory Commission 1717 H Street Washington, DC 20555
(*) - Includes Attachments 162. All others without Attachment #1 i
1 Ll/NRC/mb Revised 11/12/86
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