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M COMBUSTION ENGINEERING OWNERS GROUP

"'E."'EII/f Y T** '. 'onsYU $,'iS*'."* * ' YlU,"I.'I '''"' ' . "'d"*n','U.'' '"'* * "' . ' SoI'"E.Iff* " "' '''"*' .Arkanus Power & Light Co C rs Power Co Louiste ower & Light Co N ast Utlities Serv 6ce Co m lifornia Edison Co

Dr. Joseph K. Casper, Chairman /c/o Omaha Public Power District /1623 Harney/ Omaha, NE 68102

November 20, 1987CEOG-87-662

10CFR50 Appendix A, GDC 4

Mr. James A. NorbergDivision of Engineering and System TechnologyOffice of Nuclear Reactor RegulationU. S. Nuclear Regulatory CommissionAttn: Document Control DeskWashington, D. C. 20555

Subject: Applicability of Leak-Before-Break to the PrimaryCoolant System Piping of C-E Designed PWRs

Dear Mr. Norberg:

The purpose of this letter is to submit, for NRJ Staff review,report CEN-367, " Leak-Before-Break Evaluation of Primary CoolantPiping in Combustion Engineering Designed Nuclear Steam SupplySystems" (Enclosure 1). This report documents the applicabilityof leak-before-break to the primary coolant system piping ofCombustion Engineering designed pressurized water reactors.

The C-E Owners Group sponsored the preparation of CEN-367 to takeadvantage of changes to 10 CFR 50 Appendix A, General DesignCriterion 4, Environmental and Dynamic Effects Design Bases (newtitle). The change to GDC-4 provides regulatory relief allowingutilities to eliminate consideration of dynamic effects of piperupture from the plant design basis. The technical justificationfor the application of leak-before-break has been preparedthrough comparison to the acceptance criteria guidelines inNUREG-1061, Volume 3, " Evaluation of Potential for Pipe Breaks"and is documented in the enclosed report.

Results of the evaluations demonstrate that if a crack were tooccur it would be detectable, remain stable, and not result in aguillotine or unstable slot break. The C-E Owners Group requeststhat you review and approve report CEN-367 provided herewith asexpeditiously as possible so that participating utilities cantake advantage of the revised rule. Timely approval willpreclude the need for NRC Staff review on individual plantdockets and will allow utilities to more effectively plan forimplementation of desired plant modifications. To this end, theC-E Owners Group respectfully asks that the staff complete itsreview by June, 1988. We stand ready to be of assistance duringthe review process in order to minimize your review time.

8712030392 871120 [PDR TOPRP EMVC-E b3)Qcgecic$/8DbO IB PDR

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Mr. James A. Norberg CEOG-87-662November 20, 1987Page 2

A check (Enclosure 2) in the amount of $150.00 is provided tocover the application fee for a generic topical report review.Future correspondence regarding review fee payments should bedirected to the chairman of the C-E Owners Group.

In accordance with Dr. J. K. Gasper's letter of October 23, 1986,to Mr. Frank Miraglia (Attached), submittals made by the CEOG tothe NRC are not applicable to any individual licensee until thesubmittal is referenced by that licensee for use on his docket.Should the NRC have questions within the scope of any CEOGsubmittal, they should be addressed to the Owners Group Chairmanwith copies to the appropriate Owners Group Subcommitteechairman, C-E and each Owners Group member (appropriate addressesare attached).

If you have any questions on this matter, please do not hesitateto call me at (402) 536-4466.

Very truly yours,

*/

J. K. Gasper, hairmanC-E Owners Group

JKG/cmd

cc: Mr. F. Miraglia, NRC w/o Enclosures

Enclosures: 1) CEN-367 " Leak-Before-Break Evaluation ofPrimary Coolant Piping in Combustion Engineering

Designed Nuclear Steam Supply Systems",(23 copies)

2) Check to cover Application Fee

3) List of C-E Owners Group Members

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Q?.G)L4LQ&pi@us?:c@?YU.n wwvus M H Ws~ ). L i |< Q:Omaha Public Power District

1623 Harney Omaha. Nebraska 68102 2247 l402/536-4000

October 23, 1986

Mr. Frank Miraglia, DirectorDivision of PWR Licensing --BU. S. Nuclear Regulatory CommissionWashington, DC 20555

]Dear Mr. Miraglia:

Subject: Communications between the Combustion Engineering OwnersGroup and the Nuclear Regulatory Comission

The purpose of this letter is to inform you that I have recently re-placed Mr. R. W. Wells of Northeast Utilities as Chairman of the Com-bustion Engineering Owners Group (CEOG). The other officers of the CEOGare as follows:

Vice Chaiman Ed Sterling, Arizona Public Service

Steering Comittee Mike Meisner, Louisiana Power & LightMembers in Addition Ralph Phelps, So. California Edisonto Chaiman and Vice Tom Cogburn, Arkansas Power & LightChairman

Regulatory ResponseGroup Chaiman Ted Enos, Arkansas Power & LightVice Chairman Mark Medford, So. California Edison

Concurrent with informing you of my appointment, the CEOG has requestedthat I take this opportunity to reaffirm its established policy regardingthe subject of communications. This policy has assisted in reducing theuncertainty in detemining the communicants on issues and thereby im-proved the effectiveness of all parties concerned.

Submittals made by the CEOG to the NRC are not applicable to any individ-ual licensee until the submittal is referenced by that licensee for useon his docket. Should the NRC have questions within the scope of tr.fCE0G submittal, they should be addressed to the Ownere GPal$ Enairman,with copies to the appropriate Owners Group Subcom'.ttee chairman, C-Eand each Owners Group member. The individuals to whom copies should beaddressed will be identified with each Owners GrcJp submittal.

.

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Questions from the NRC on issues beyond the scope of previous sub-mittals made by the CE0G should be addressed only to the individuallicensees. The licensees will then consider the extent of the CEOGinvolvement, if any, in an appropriate response.

At times in the past, the NRC has provided items to the CEOG Chairmanfor the information and use of CEOG members. Such items should now besent to me with a copy to C-E (James W. Pfeifer).

The CEOG feels that this communications policy serves the best interestsof the Owners Group, individual licensees and the NRC.

If you or your staff have any questions concerning this topic, or anytopic pertaining to the CEOG, please contact me at (402)536-4555. Ifsending Federal Express, our street address is 1623 Harney Street,Omaha, NE 68102.

Sincerely,

J. K. (Joe) GasperChairmanC-E Owners Group

JKG/jb

cc: Dennis Crutchfield, NRCHarold Denton, NRC

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C-E Owners Group Members

Mr. A. J. Wrape, III Mr. Kenneth BerryArkansas Power & Light Co. Consumers Power Co.Capitol Towers Building 1945 West Parnall RoadCapitol and Broadway Jackson, MI 49201Little Rock, AR 72203

Mr. Michael Meisner Mr. John HutchinsonLouisiana Power & Light Co. Florida Power & Light Co.317 Baronne Street (Fourth Floor) P. O. Box 14000New Orleans, LA 70160 Juno Beach, FL 33408

Mr. Rik Wells Mr. G. Douglas WhittierNorthest Utilities Service Co. Maine Yankee Atomic Power Co.107 Seldon Street Edison DriveBerlin, CT 06037 Augusta, ME 04336

Mr. Robert Ash Dr. Joseph K. GasperBaltimore Gas & Electric Co. Jones Street StationCalvert Cliffs Nuclear Power Plant Omaha Public Power DistrictRoutes 2 & 4 1623 Harney Street iLusby, MD 20657 Omaha, NE 68102

Mr. Ralph L. Phelps Mr. Edward SterlingSouthern California Edison Co. Arizona Public Service Co.2244 Walnut Grove Avenue 11226 N. 23rd AvenueRosemead, CA 91770 Phoenix, AZ 85029

Analysis Subcommittee Chairman

Mr. Jerry HolmanMail Unit 46Louisiana Power & Light Co.317 Baronne StreetNew Orleans, LA 70160

Combusion Engineering Contact

Mr. James W. PfeiferCombustion Engineering, Inc.1000 Prospect Hill RoadP. O. Box 500Windsor, CT 06095-0500

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