ML20205C526

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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
ML20205C526
Person / Time
Site: Beaver Valley
Issue date: 08/07/1986
From: Carey J
DUQUESNE LIGHT CO.
To: Harold Denton, Tam P
Office of Nuclear Reactor Regulation
References
RTR-NUREG-1061 2NRC-6-079, 2NRC-6-79, GL-84-04, GL-84-4, TAC-62883, NUDOCS 8608120347
Download: ML20205C526 (3)


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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

8608120347 860807 0

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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