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Comment here: http://www.regulations.gov/#!documentDetail;D=NRC-2015-0088-0001

Names like ASME RR and ASME 13R are NOT safety codes or standards. They are “Regulatory Relief”-exemptions from ASME safety standards, given by the US NRC to the nuclear utilities. It seems that safety standards make the nuclear utilities constipated as they request constant “regulatory relief”. Although the Wikipedia article and the NRC draft Pressurized Thermal Shock Rule say ASME was “formerly” the American Society of Mechanical Engineers, the ASME web site is still copyrighted American Society of Mechanical Engineers. One has to wonder if it’s because the nuclear industry wants to make sure that there are no Mechanical Engineers to out their lies and wants to pack ASME with the farcical degree called nuclear engineering to make farcical “regulatory relief standards” the norm? A good sociologist could out the nuclear industry-NRC’s outrageous playing with statistics. For that matter, the nuclear industry-NRC generally fail methodology along with both quantitative and qualitative methods – whether from the hard sciences or social sciences, and probably even get lost within airplane toilets.

One of the NRC laundry list sneak throughs is to put plastic HDPE piping, which is petroleum based and melts and burns at low temperatures, for the above ground Essential Service Water system (EWS). Essential Service Water system (ESW) for Nuclear Power Stations – the name says it all and plastic pipes are clearly unacceptable and they are against ASME standards.

Hence, the US NRC devised an ASME RR, which means “regulatory relief” from the ASME rules. Being petroleum based, HDPE produces toxic fumes as it burns. This egregious idea appears especially dangerous since the Callaway Nuclear Power Station is 5 miles from the Missouri River. So, what will they do when the pipes are melted from fire and the workers passed out from toxic fumes? Fires occur in nuclear reactors fairly frequently, shockingly enough.
Callaway Nuclear Generating Station
All water lost through evaporation or blowdown is replaced with water from the river, located five miles from the plant. The temperature of the water going into the cooling tower is 125 °F (52 °C), and the tower cools it to 95 °F (35 °C). http://en.wikipedia.org/wiki/Callaway_Nuclear_Generating_Station

Not only is the use of plastic piping above ground at nuclear power stations in violation of ASME code, it probably would be uninsurable and the nuclear utility is supposed to carry a small amount of insurance above the Price Anderson Insurance pool, which is to be paid into only after nuclear disaster by the utilities and will be paid for by the ratepayers and, ultimately, possibly by the taxpayer. The almost total lack of liability due to the Price Anderson Act is clearly the reason that the nuclear utilities are constantly trying to undermine health and safety with “regulatory relief”. https://miningawareness.wordpress.com/2015/05/09/price-anderson-act-billions-in-bailout-for-nuclear-disasters/ But, why is the US NRC the nuclear industry’s jump and fetch dog?

The HDPE pipes are also less resistant to pressures from cavitation -voids or air in the line, water hammer – hydraulic shocks. http://en.wikipedia.org/wiki/Cavitation http://en.wikipedia.org/wiki/Water_hammer

The HDPE plastic can only withstand 120 °C/ 248 °F temperatures for short periods, and 110 °C /230 °F for longer periods. http://en.wikipedia.org/wiki/High-density_polyethylene
As a point of comparison, a candle (air-paraffin) burns at around 1,000 °C (1,800 °F), a smoldering cigarette: temperature without drawing: side of the lit portion; 400 °C (750 °F); middle of the lit portion: 585 °C (1,100 °F); temperature during drawing: middle of the lit portion: 700 °C (1,300 °F), and blowtorch (air-mapp gas) burns at 2,200 °C (4,000 °F). http://en.wikipedia.org/wiki/Fire

Interestingly enough, neither the utility nor the US NRC deny that the HDPE melts, burns and creates toxic fumes. In fact, they state that it does! (See below) They just don’t consider it a problem. It’s really hard to see what alternate water source they imagine either with the river 5 miles away.

Another, related topic, brought up for comment is “Protection Against Pipe Whip“. The HDPE pipe has more built-in energy making it more flexible and springy than metal piping. In the event of breakage-failure it is thus more likely to fly through the air and puncture something else.

If they have already laid underground plastic piping they may need to dig it up and re-lay metal piping, due to difficulties which arise joining metal and plastic together.

From the NRC:
March 31 2015
[…]
The ESW system provides a heat sink for the removal of process and operating heat from safety-related components during a design-basis accident or transient. During normal operation and a normal shutdown, the ESW system also provides this function for various safety-related and non-safety related components and receives coolant flow from the non-safety related service water system. The principal safety-related function of the ESW system is the removal of decay heat from the reactor via the component cooling water system and removal of containment heat loads via the containment coolers.

The ESW system consists of two separate, 100 percent capacity, safety-related, cooling water trains A and B. Each train consists of a self-cleaning strainer, pre-lube tank, one 100-percent capacity pump, piping, valves, and instrumentation. The pumps and valves are remotely and manually aligned, except in the unlikely event of a loss-of-coolant accident. The pumps are automatically started upon receipt of a safety injection signal, low suction pressure to the auxiliary feedwater pumps coincident with an auxiliary feedwater actuation signal, or loss of offsite power. Upon receipt of one of these signals, the automatically actuated essential valves are aligned to their post-accident positions as required. The ESW system also provides emergency makeup to the spent fuel pool and component cooling water system and is the backup water supply to the auxiliary feedwater system.

The ultimate heat sink (UHS) provides a heat sink during a transient or accident, as well as during normal operation, via the ESW system. The two principal functions of the UHS are the dissipation of residual heat after reactor shutdown and dissipation of residual heat after an accident.

2.0 REGULATORY EVALUATION

The licensee’s proposed amendment would allow use of a new pipe crack exclusion allowance for HDPE piping installed in ASME Code, Section III, Class 3 line segments of the ESW system. The proposed amendment would revise the licensing basis as described in FSAR-Standard Plant Section 3.6.2.1.2.4 related to ASME Code, Section III and Non-Nuclear Piping of Moderate-Energy, and FSAR-Standard Plant Table 3.6-2, Design Comparison to Regulatory Positions of Regulatory Guide (RG) 1.46 (Reference 7), Protection Against Pipe Whip Inside Containment, for the HDPE piping installed in ASME Code, Section III Class 3 line segments of the ESW system….
The proposed change, which involves applying an alternate method to add a low stress, LEAKAGE CRACK EXCEPTION for HDPE piping, represents a change in method for postulating moderate energy leakage cracks…
The NRC staff evaluated the fire hazard of non-buried portions of HDPE piping to safety-related ASME Code Class 3 components in the ESW system. EXPOSED HDPE PIPING is installed in the CBS, the UHS Penetration Room, and the Yard Vault, which MAY BE SUBJECT TO DAMAGE IF A FIRE WERE TO OCCUR
As discussed in the NFPA 805 safety evaluation, the licensee concluded that no fire damage to the HDPE piping would occur, and the NRC staff accepted this conclusion in the January 13, 2014, safety evaluation.

For the UHS Penetration Room and the Yard Vault, the licensee has evaluated that for each of these areas redundant ESW system capability is available in the event of the loss of integrity of the HDPE piping in these areas. IN THE EVENT OF A FIRE IN THESE TWO AREAS, THE LICENSEE ASSUMES THAT THE HDPE PIPING WOULD FAIL
Principal Contributor: C. Basavaraju, NRR/DE/EMCB
Date: March 31, 2015 …
Sincerely,
IRA Balwant Singal for
Carl F. Lyon, Project Manager Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
” (Caps added with emphasis) http://pbadupws.nrc.gov/docs/ML1506/ML15064A028.pdf

Clear concerns actually laid out by the NRC on
Dec 11, 2014
DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO. FACILITY OPERATING LICENSE NPF-30 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ROUND 2 RE: APPLICATION FOR AMENDMENT TO FACILITY OPERATING LICENSE NPF-30 REVISION TO FINAL SAFETY ANALYSIS REPORT STANDARD PLANT SECTION 3.6 FOR HIGH DENSITY POLYETHYLENE PIPE CRACK EXCLUSION (TAC NO. MF3202, LDCN 13-0016)…

[…]
By application dated December 6, 2013 (Reference 1 ), as supplemented by letter dated September 2, 2014 (Reference 2), to the U.S. Nuclear Regulatory Commission (NRC), Union Electric Company (dba Ameren Missouri, the licensee) submitted a license amendment request (LAR) to revise the Final Safety Analysis Report-Standard Plant (FSAR-SP) Section 3.6.2.1.2.4, “ASME [American Society of Mechanical Engineers] Section Ill and Non-Nuclear Piping – Moderate-Energy,” to include a new pipe crack exclusion allowance at Callaway Plant, Unit 1… The HOPE piping is not designed using the Code Equations from ASME Section III. It is installed in an ASME Section III, Class 3 system. The design was approved by the NRC in Relief Request 13R-1 0. The approved design principals are contained in Callaway procedure APA-ZZ-00662 Appendix F and follow those contained in Code Case N-755-1. Note that the use of Code Case N-755-1 was not part of the relief request. As stated above, APA-ZZ-00662 Appendix F contains the design principles for the HDPE pipe….
Provide a brief discussion related to the fire hazard of the non-buried sections of the HDPE piping in the Control Building Basement, in the Ultimate Heat Sink (UHS) Penetration Room, and in the yard vault on any safety related commodities in the vicinity. Please also address fire resistance characteristics of the insulation, and any wrapping used on the HDPE piping.

Response: HDPE Pipe Fire Hazard The HDPE pipe which is composed of high density polyethylene is considered a combustible material; however; its ignition temperature is >300 degrees C and auto-ignition temperature is 349 degrees C. If ignited, HDPE pipe will create dense smoke. The exposed HDPE pipe fire hazard could be considered comparable to electrical cable trays filled with IEEE rated electrical cables which are used throughout the plant in terms of its susceptibility to ignition and its smoke generation should it be ignited. The HDPE pipe is not an ignition source, and its addition does not affect the probability of a fire occurring in any fire area.” ML14345B052
http://pbadupws.nrc.gov/docs/ML1434/ML14345B052.pdf
IT’S ADDITION MAY NOT AFFECT THE PROBABILITY OF A FIRE, HOWEVER, IT DOES INCREASE RISKS IN THE EVENT OF SUCH A FIRE! MAYBE THEY NEED NON-FLAMMABLE COVERS FOR THEIR ELECTRICAL CABLES? THEY ARE TO LOSE BOTH ELECTRICITY AND ESSENTIAL WATER IN CASE OF FIRE?

Here is one page which offers a clear view of the insanity at hand. This is from a December 11, 2014 request for more information by the NRC. It illustrates the owner of the Callaway Nuclear Power Station, Ameren’s, hopelessly insane and inane responses.
ULNRC-06152, p. 3 ML 14345B052 Dec. 11 2014 Request for addnal info
Dec. 11, 2014, UL NRC-06152, p. 3, Adams No.: ML14345B052
More from:
March 31 2015
The amendment adds a new pipe crack exclusion allowance to FSAR-Standard Plant Section 3.6.2.1.2.4, “ASME [American Society of Mechanical Engineers] Section Ill and Non-Nuclear Piping-Moderate-Energy,” and FSAR-Standard Plant Table 3.6-2, “Design Comparison to Regulatory Positions of Regulatory Guide 1.46, Revision 0, dated May 1973, titled ‘Protection Against Pipe Whip Inside Containment,”‘ in particular regard to the high-density polyethylene (HOPE) piping installed in ASME Class 3 line segments of the essential service water system.
” Full Nonsensical document: http://pbadupws.nrc.gov/docs/ML1506/ML15064A028.pdf

Additional Information-References

Callaway Plant, Unit 1, Request for Additional Information, Round 3, Dec 22, 2014 – revise the Final Safety Analysis Report-Standard Plant (FSAR-SP) Section 3.6. 2.1.2.4, “ASME. [American Society of Mechanical Engineers]…
pbadupws.nrc.gov/docs/ML1435/ML14353A117.pdf

Callaway Plant, Unit 1 – Request for Additional Information, Round 2 Oct 28, 2014 – … the Final Safety Analysis. Report-Standard Plant (FSAR-SP) Section 3.6.2.1.2.4 , “ASME [American Society of Mechanical. Engineers] Section” pbadupws.nrc.gov/docs/ML1429/ML14294A775.pdf

Callaway Plant, Unit 1 – Request for Additional Information, License Jul 1, 2014 – … the Final Safety Analysis Report-Standard Plant (FSAR-SP). Section 3.6.2.1.2.4 , “ASME [American Society of Mechanical Engineers] Section …
pbadupws.nrc.gov/docs/ML1417/ML14178A823.pdf

A document re Callaway: http://pbadupws.nrc.gov/docs/ML1431/ML14310A836.pdf

Callaway Plant, Unit 1, Response to Request for Additional Information, Feb. 3, 2015
pbadupws.nrc.gov/docs/ML1503/ML15034A615.pdf

Protection Against Pipe Whip Inside Containment.
pbadupws.nrc.gov/docs/ML1229/ML12298A123.pdf
REGULATORY GUIDE 1.46. PROTECTION AGAINST PIPE WHIP INSIDE CONTAINMENT. A. INTRODUCTION. General Design Criteron 4, “Environmental and Pipe Break Effects on Systems and Components Inside Containment“. pbadupws.nrc.gov/docs/ML0717/ML071780289.pdf
element program to estimate the effect of a pipe whip on the containment wall. … components important to safety be appropriately protected against the …

Callaway is owned by Ameren Corp.: Fadi M. Diya is Sr VP and Chief Nuclear Officer, Ameren Missouri at Ameren Corporation His Salary and Bonus is $669,977 and stock awards is $986,729

[1] “The “adiabatic flame temperature” of a given fuel and oxidizer pair indicates the temperature at which the gases achieve stable combustion.”
http://en.wikipedia.org/wiki/Fire

EMPHASIS ADDED THROUGHOUT POST.