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MONTHYEARML20134F3711985-08-12012 August 1985 Notification of 850827 Meeting W/Util & S&W in Bethesda,Md to Discuss Alternate Pipe Rupture Protection Project stage: Meeting ML20133H9491985-10-10010 October 1985 Forwards Proprietary Whipjet Program, Re Improved Means for Determining Necessity to Install Mechanical Devices to Protect Equipment & Structures from Effects of Pipe Breaks. Program Withheld (Ref 10CFR2.790) Project stage: Other ML20137C0041986-01-0909 January 1986 Discusses Four Areas of ACRS Interest Resulting from Review of ACRS Rept.No Opponent Connection Found Between Four Areas & Schedule for Sser 1 Project stage: Other ML20153H1021986-02-18018 February 1986 Notification of 860304 Meeting W/Util in Bethesda,Md to Discuss Progress in Whipjet Program Project stage: Meeting ML20154M6371986-03-0606 March 1986 Notification of 860313 Meeting W/Util in Bethesda,Md to Discuss Util Progress in Whipjet Program (Use of leak- before-break Assumption for Balance of Plant Piping) Project stage: Meeting ML20199E3861986-03-18018 March 1986 Summary of 860304 Meeting W/Util,Novetech Corp,Rl Cloud Assoc,Epri & S&W Re Progress on Whipjet Program.Attendee List Encl Project stage: Meeting ML20199D9091986-03-18018 March 1986 Notification of 860410 Meeting W/Util in Bethesda,Md to Discuss Util Progress W/Whipjet Program for Use of leak-before-break Assumption for balance-of-plant Piping. List of Attendees Provided Project stage: Meeting ML20199J6361986-03-31031 March 1986 Summary of 860312 Meeting W/Util Re Second Progress Report Meeting on Whipjet Program.Viewgraphs,Attendee List,Agenda & Summary of Questions Raised by NRC Encl Project stage: Meeting ML20141J1031986-04-16016 April 1986 Notification of 860520 Meeting W/Util in Bethesda,Md to Discuss Progress of Whipjet Program Re Use of leak-before-break Assumption for balance-of-plant Piping Project stage: Meeting ML20203C2071986-04-16016 April 1986 Summary of Third Progress Rept 860410 Meeting W/Epri,S&W, Novetech Corp & Rl Cloud Assoc to Discuss Progress in Whipjet Program Re Use of leak-before-break Assumption on balance-of-plant Piping Project stage: Meeting IR 05000334/19860061986-05-0101 May 1986 Insp Rept 50-334/86-06 on 860311-0418.Violations Noted: Failure to Assess RHR HX Outlet Temp Remote Shutdown Monitoring Instrumentation Channel as Inoperable.Deviation Noted:Poor Quality Welds on Fuel Oil Day Tank Supports Project stage: Request ML20203P9661986-05-0101 May 1986 Forwards Request for Addl Info & Formal NRC Position Re Whipjet Program.Request Also Contains Addl Questions from Review of 860410 Draft Progress Rept.Response Requested Prior to Next Whipjet Meeting on 860520 Project stage: Draft RAI ML20205S5961986-05-29029 May 1986 Summary of 860520 Meeting W/Util Re Progress in Whipjet Program (Use of leak-before-break Assumption on balance-of- Plant Piping).List of Attendees Encl Project stage: Meeting IR 05000412/19860121986-06-18018 June 1986 Insp Rept 50-412/86-12 on 860510-0613.No Violation or New Safety Problems Noted.Major Areas Inspected:Preoperational Program Implementation,Rcs Hydro Test Evaluation,Exhaust Hood Insulation Failures & RCS Cleanup Project stage: Request ML20204E9281986-07-24024 July 1986 Notification of Fifth Progress Rept Meeting W/Util on 860827 in Bethesda,Md to Discuss Progress in Whipjet Program Re Use of leak-before-break Assumption for balance-of-plant Piping Project stage: Meeting ML20204H3281986-08-0404 August 1986 Notification of 860813 Meeting W/Util in Bethesda,Md to Discuss Issues Re Whipjet Program (Use of leak-before-break Assumption to balance-of-plant Piping),Including Leak Detection Margin & Schedular Exemption to GDC 4 Project stage: Meeting ML20205C5261986-08-0707 August 1986 Expresses Appreciation for Arranging 860813 Alternate Pipe Rupture Protection Program (Whipjet) Meeting Between NRC & Util in Bethesda,Md to Resolve Issues Re Schedular Exemption & Leak Detection Safety Margin Project stage: Meeting ML20209F8611986-09-0909 September 1986 Requests 860916 Meeting in Boston,Ma to Discuss,In Detail, Response to Questions Provided During Fifth Progress Rept Meeting on Whipjet Issues Project stage: Meeting ML20203M9971986-09-12012 September 1986 Forwards NRC Positions & Request for Addl Info Re Whipjet Program (Application of leak-before-break Criteria to balance-of-plant Piping).Major Problem Areas Include Lack of Matl Test Data & Detectable Leak Rate for Ferritic Piping Project stage: RAI ML20210J5601986-09-22022 September 1986 Summary of 860827 Fifth Progress Rept Meeting W/Util, Westinghouse,Rl Cloud Assoc,S&W,Novetech,Etec,Epri & Bechtel Re Whipjet Program.Agenda & List of Attendees Encl Project stage: Meeting ML20211E9601986-10-23023 October 1986 Forwards Whipjet Program Rept & Proprietary App B, Stainless Steel Matl Properties Re Alternate Approach to Pipe Break Protection for balance-of-plant Piping. Expeditious Review Requested Project stage: Other ML20214E2851986-11-17017 November 1986 Forwards Proprietary App C to Whipjet Final Rept,Containing Info Re Properties of Ferritic Steel Base & Weld Metals. Application for Withholding Encl.Proprietary App C Withheld (Ref 10CFR2.790) Project stage: Request ML20207Q1531987-01-14014 January 1987 Notification of 870116 Meeting W/Util in Bethesda,Md to Discuss Applicant Personnel Issues That Arose as Result of NRC Review of Whipjet Program Rept Project stage: Meeting ML20210A9041987-02-0202 February 1987 Requests Partial Exemption from GDC 4 of 10CFR50,App a by Applying leak-before-break Technology as Alternative to Providing Hardware & Proprietary Withholding of App B to Whipjet Program Rept (Ref 10CFR2.790).Encl Withheld Project stage: Other ML20210T5651987-02-11011 February 1987 Summary of 870116 Meeting W/Util Re Issues That Remained Open as Result of Review of Whipjet Final Rept . Suggests Applicant Submit Formal Request for Exemption from GDC 4 for Piping Addressed in Rept.Related Info Encl Project stage: Meeting ML20210S8801987-02-11011 February 1987 Forwards Review Comments on Proof & Review Tech Specs,Per NRC 870128 Request Project stage: Other ML20204J2431987-02-13013 February 1987 Forwards Details of Changes to Whipjet Program Rept, Including Clarifications & Reanalysis of Some Fracture Mechanics Calculations,Resulting in Data Somewhat Different than Data Transmitted in Rept by .W/O Rept Project stage: Other 1986-05-29
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2NRC-6-079 Beaver Valley No. 2 Unit Project organization Telecopy 643-52 Ext.160 k.h. so"[$2$"'
August 7, 1986 Shippingport, PA 15077 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Mr. Peter Tam, Project Manager Division of PWR Licensing - A Office of Nuclear Reactor Regulation
SUBJECT:
Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 Alternate Pipe Rupture Protection Program (WHIPJET)
REFERENCE:
NRC Generic Letter 84-04, " Safety Evaluation of Westinghouse Topical Reports Dealing With Elimination of Postulated Pipe Breaks in PWR Primary Main Loops", signed by D. G. Eisenhut, February 1, 1984.
Gentlemen:
Your arranging a WHIPJET meeting for August 13, 1986 between NRC personnel and Duquesne Light Company representatives in Bethesda, Maryland is greatly appreciated.
The purpose of this meeting is to resolve two general issues:
(1)
The plan for schedular exemption for the pipe rupture hard-ware being evaluated in the WHIPJET program, and, (2)
The safety margin of 10 on leak detection capability and leak rate prediction for postulated through-wall cracks.
The schedular exemption issue requires clarification so that Beaver Valley Unit 2 construction schedules can be maintained to meet the planned fuel load date in April 1987.
Although a March 3,1986 letter to Duquesne Light Company indicates that a schedular exemption is indeed possible, some confusion exists which needs resolution.
The other issue that needs immediate attention is that of the margin to be applied on the calculated leak rates for cracks less than or equal to one-half critical size.
The NUREG 1061, Volume 3 methodology specifies that a margin be applied, but does not provide a specific number.
The analysis discussed in Reference 1 for the primary loop piping, which led to the limited scope rule change to GDC-4, used a margin of 10 because it was easily obtained for this large diameter piping.
Also, the July 23, 1986 publication in the Federal Register of the proposed broad scope change 5
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PDR ADOCK 0500 2
United Stat'es Nuclear Regulatory Commission Mr. Harold R. Denton, Director Alternate Pipe Rupture Protection Progran (WHIPJET)
Page 2 mentions this same factor of 10.
We believe that this factor of 10 used for the pimary system piping is inappropriate for the balance-of-plant pip-ing under evaluation at Beaver Valley Unit 2.
We would like to propose a more appropriate approach and will discuss the background, rationale, and justification for our method.
Some of the technical background related to this issue is given below.
(1)
The original use of the factor of 10 in Reference A was the result of calcul ations showing that even with an ex-ceedingly high margin of 10 on leak detection, the large diameter primary piping was still acceptable for leak-before-break.
(2)
The EPRI PICEP computer code for calculating leak rates has been verified and shown to be accurate within a + 25% band.
The issue of crack plugging has also been resolved by com-parison with experimental values.
(3)
NUREG 1061, Volume 3 states that the safety margin of 2 on critical crack size is intended ".
.to account for the uncertainties inherent in the analyses and leak detection c apabil i ty."
Thus a significant margin on leak detection already exists in the safety margin on crack size.
(4)
The excess margin on crack stability for the exceedingly high loads of 1.4 x (nonnal + SSE) on the 0.5 critical size crack substantially reduces or eliminates the need for the margins on leak rate.
These technical issues will be discussed with you and your colleagues at the August 13th meeting.
We will recommend that the safety margin on leak detection be established as a range for balance-of-plant piping.
Also with respect to leak detection capability, there have been some implications that less than 0.5 gpm leakage inside containment (with the margin of 10 also applied) will not be acceptable.
We believe each individual break lccation should be evaluated separately and a specific threshold with regard to leakage and detection time be established rather than imposing a somewhat arbitrary general limit.
We hope to receive your specific comments on this related issue also.
United Stat'es Nuclear Regulatory Commission Mr. Harold R. Denton, Director Alternate Pipe Rupture Protection Prog an (WHIPJET)
Page 3 Please let us know if you wish any further clarifications before our meeting date.
DUQUESNE LIGHT COMPANY DI4 By J. J. Carey u
Vice President JJS/ijr NR/WHIPJET cc:
Mr. W. Troskoski, Sr. Resident Inspector Mr. L. Prividy, Resident Inspector l
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