ML20101S844
| ML20101S844 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 01/31/1985 |
| From: | Woolever E DUQUESNE LIGHT CO. |
| To: | Knighton G Office of Nuclear Reactor Regulation |
| References | |
| 2NRC-5-014, 2NRC-5-14, NUDOCS 8502050669 | |
| Download: ML20101S844 (9) | |
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!$((5!5!f Nuclear Construction Division Telecopy (412) 787-2629 Robinson Plaza. Building 2, Suite 210 Pittsburgh, F A 15205 January 31, 1985 United States Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Mr. George W. Knighton, Chie f Licensing Branch 3 Of fice of Nuclear Reactor Regulation
SUBJECT:
Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 Preservice Inspection Program - Class 2 Piping Examinations, ASME Section XI PSI Program Gentlemen:
This letter rescinds the prior request by Duquesne Light Company (DLC) for Nuclear Regulatory Commission approval of use of the 1983 Edition Winter 1983 Addenda of ASME Section XI for Class 2 piping examination stated in the referenced letter.
As a result of direct discussions with your staff personnel, DLC requests approval of the following methodology, applicable to Class 2 piping examination during Preservice Inspection (PSI):
1.
The basis for examination of welds is 80W80 for ' Volumetric and Surface" examination, including 74S75 requirements identified in 10CFR50.55 a.
2.
The 83W83, Table IWC-2500-1, Categories C-F-1 and C-F-2 will be utilized as guidance in establishing additional welds for exami-
- nation, for compatibility with anticipated ISI req uirements.
However, a 10 percent sample criteria will be utilized in lieu of the 7.5 percent sample criteria for stainless steel systems (carbon steel systems are not effected by sampling percentage change, as minimum number of examinations takes ' precedence).
3.
Welds which are ident ified requiring Augmented ISI (volumetric ins pect ion only) will be ultrasonically inspected during PSI.
These welds are located in the identified Break Exclusion Zone for Main Steam System (MSS), Feedwater System (FWS), and Steam Vent System (SVS), located outside containment (see Attachment 2 for specific jurisdication boundaries of BVPS-2 Break Exclusion Zone).
4.
The combination of Items 1 through 3 above increases the volumet-ric examinations vs.
the 80W80 (with 74S75) basis and also increases the vo lume t ric examinations vs.
the 83W83 guidance.
The total number of examinations (" surface only" plus " volumetric l
8502050669 850231 gDRADOCK 05000412 Ig PDR a
' United States Nuclear Rsgulatory Commission Mr. George W. Knighton', Chief Page'2 and surface") exceeds the 80W80 total number of examinations through inclusion of Augmented ISI requirements in the PSI program, maintenance of 80W80 " unique" and 80W80/83W83 " common",
and addition of the 83W83 " unique" nonexempt welds, even when unique 80W80 " surf ace only" welds - are deleted.
Therefore, DLC requests deletion of the 80W80 " unique" " surf ace only" examina-tions ( 39 9) as they will not be required for examination by future Code Edition / Addenda (i.e.
83W83, etc. ).
5.
DLC has included provisions for weld profiling (preparation for volumetric examination) " additional" welds which may require
" volumetric and surface" examination in accordance with 80W80 IWC-2430 in its program.
In selection of.these welds, location, accessibility, and ALARA concerns were included.
As ' identified in the December 12, 1984, meeting with your staf f at Bethesda,-MD, DLC has included (as Attachment 1) modified tables for stain-less steel and carbon steel systems.
These tables identify the 80W80 BVPS-2 the 83W83 BVPS-2 welds utilized as guidance; aiugmented ISI welds; and welds ;:
a composite " Supplemental PSI Plan," which integrates these elements.
Therefore,.DLC requests NRC. approval of the " Supplemental PSI Plan."
. Please. notify ' us by. March 1,
1985, of the closed, conformatory, or open status of this element of the PSI' Program and how you intend to treat this element in the Safety Evaluation Report.
DUQUESNE LIGHT COMPANY By E. 0.~Woolever Vice President JJS/wjs
- Attachment Mr. B. Brown, EG&G (w/a).
cc: - Mr. S. Chang, NRC (w/a)
'Mr.'M. Hum, NRC (w/a)
' Mr. ~ B. K. Singh, Project Manager. (w/a)
^
~Mr. G. Walton, NRC Resident Inspector (w/a) 7
Reference:
2NRC-4-171, dated October ~ 19, 1984
~
SUBSCRIBE" AND SWORN TO BEFORE^ME THIS 3/.uf DAY OF (LWow
,-1985.
Slx Ll BEG Notary Public ANITA ELAINE REITER, NOTARY PUBUC -
ROBINSON TOWNSHIP, ALLEGHENY COUNTY MY COMMISSION EXPIRES OCTOBER 20,1986 4 n-
Unitsd Stctso Nuclect Rsgulttory Commission
' Mr. Georgs W. Knighton, Chief
' Page 3 COMMONWEALTH OF PENNSYLVANIA ))
SS:
- COUNTY OF ALLEGHENY
)
On this d/M day of
/W4M'/-
_ /ff 6, before me, a V
Notary Public in and for said Co/mmo nwealth and County, personally appeared
/
E. J. Woolever, who being _ duly sworn, deposed and said that (1) he is Vice President of.- Duquesne Light, (2) he is duly authorized to execute and file the foregoing Submittal on behalf of said Company, and (3) the statements
. set forth in the Submittal are true and ::orrect to the best of his knowledge.
fe t [_
v Notary Public ANITA ELAINE REITER, NOTARY PUBLIC ROBINSON TOWNSHIP, ALLEGHENY COUNTY MY COMMISSION EXP!RES OCTOBER 20,1986 T
/
fr N
-en.
-]
ATTACHMENT 1 TABLE 1 c.
. CLASS.2 PIPING. WELD EXAMINATION
SUMMARY
SHEET Sect. XI, Table IWC-2500-1, Exam. Cat.~C-F-1 (Sheet 1 of ' 2)
STAINLESS STEEL' SYSTEMS:
1 2
'3 4
5 6
7 8
9 10 11=
12 13 14 74S75 Sect. XI Rules 83W83 Sect. XI Guidance Using 10% Selection Nonexempt Welds ISI Req'd Exams Nonexempt Welds ISI Reg'd Exams l Vol i I vol l'
I vol-I I
10.0% 3
' Vol System Surf + and = Total Surf + and = Total Surf + and + Exam = Total As % of Prorata = Surf + and Only i Surf,
only i Surfi Only i Surfi N/A i SS Welds Share i Onlyi Surf CHS 108 0
108 52 0
52 526 431 108 1065 41.009 107 59 48 QSS
Exempt IWC.- 1220 (b) ---
0 47 125 172 6.623 17 0
17 RHS 212 2
214 107 1
108-0 64 203 267 10.281 27 0
27 0
126 28 154 5.930 15 0
15 Exempt IWC - 1220 (b)
RSS SIS 342 151 493 217 88 305 176 494 269 939 36.157 94 26 68 662 153 815 376 89 465 702 1162 733 2597 100 260 85 175 g
NOTES:
A.
10CFR50. 55a (b) (2) (iv) invokes requirements to use the 74S75 Code for the above systems to deter-mine only exemption criteria (IWC-1220) and selection criteria (IWC-2411 and Table IWC-2520, Cat. C-F and C-G).
The preservice requirement and the specific required examination method remain in accordance with the Code of choice, namely 80W80.
The high number of welds in the CHS and SIS Systems which are candidates for surface and not B.
volumetric examinations under the 83W83' Code is due largely to the fact that 2" NPS lines in these. systems are of socket weld construction.
C.
Exemption IWC-1220 (b) : Components in systems or portions of systems, other than emergency core cooling systems, which do not function during normal reactor operation.
t
TABLE 1 CLASS 2 PIPING WELD EXAMINATION
SUMMARY
SHEET
[,,, #
Sect. XI, Table IWC-2500-1, Exam. Cat. C-F-2 (Sheet 2 of 2)
CARBON STEEL SYSTEMS:
1 2
3 4
5 6
7 8
9 10 11 12 13 14 80W80 Sect. XI Rules 8 3W83 Sect. XI Rules Nonexempt Welds ISI Reg'd Exams Nonexempt Welds ISI Reg'd Exams i Vol i I Vol I I
Vol I i
7.5% '
vol System Surf + and = Total Surf + and = Total Surf + and + Exam = Total As % of Prorata = Surf + and Onlyi Surfi Onlyi Surf i
$2 52 0
13 13 0
52 0
52 27.660 8
0 8
MSS 3
71 74 1
16 17 3
71 0
74 39.361 11 1
10 SVS 96 0
96 24 0
24 0
62 0
62 32.979 9
0 9
i 99 123 222 25 29 54 3
185 0
188 100 28 1
27 Subtotal 260 85 175 662 153 815 376 89 465 702 1162 733 2597 288 86 202 Total 761 276 1037-401 118 519 705 1347 733 2785 NOTE: A decrease of one weld which is required to be volumetrically examined is realized by moving to the 83W83 Code (columns 5 and 14). However this is offset by the fact that the major portion of the nonexempt
~
weld candidates are located in the " break exclusion zone" which is subject to an augmented volumetric examination program during the operating phase of the plant. Therefore, additional welds will be
' volumetrically examined during each inservice inspection interval.
i Advantage of Utilizing the 83W83 Code for CS Systems:
SVS is now included in the population subject to volumetric examination due to inclusion of 3/8" through 1/2" wall under this examination requirement.
PSI compatability with the ISI Program.
L
TABLE 2 Sheet 1 of 2 BVPS-2 REQ'D EXAMS & SUPPLEMENTAL PSI PLAN SURF. ONLY VOL. & SURF.
VOL. ONLY Unique Common Unique Unique Common Unique (Augmented delta System 80 80&83 83 80 80&83 83 from PSI, Note 1)
Total CHS 52 XXX 59 0
XXX 48 N/A 159 Note 2 QSS 0
XXX 0
0 XXX 17 N/A 17 RHS 107 XXX 0
0 1
26 N/A 134 Note 3 RSS 0
XXX 0
0 XXX 15 N/A 15 SIS 216 1
25 69 19 49 N/A 379 Notes 4,5 FWS 0
XXX 0
6 7
1 28 42 Notes 1,6,7 MSS 0
1 0
6 10 0
67 84 Notes 1,7,8 t-SVS 24 XXX 0
0 0
9 100 133 Notes 1,9 l
399 2
84 81 37 165 195 963 E
Delete all one time ' unique 80' surface exams, Notes 2, 3,4,8 399 l
564 NOTES:
1.
Those welds which receive an Augmented inspection do not include in the count those welds in the " break-exclusion zone (BEZ)" which receive a section XI
~
volumetric and surface examination superseding the Augmented volumetric exami-nation requirement, thus a delta is shown.
Aug. Total
= Aug. Delta
+ Sect.
XI "BEZ" 28
+
4 FWS:
32
=
MSS:
74 67
+
7
=
100
+
9 SVS:
109
=
216 115 Ao
-2.
The 52 ' unique 80' CHS surface exams occur on the low pressure 6 & 8" NPS suction side of the charging pumps. In 83, emphasis is shif ted to inspection of the high pressure pump discharge piping including line sizes down to 2" NPS. These 52
' unique 80' welds remain as part of the nonexempt population affecting the determination of the number cf examinations for this system, but are themselves not subject to examination under 83W83 Rules, i.e., they become part of the 108 Exam N/A population (less than.375" wall) from the previous Table.
TABLE 2 Sheet 2 of 2 3.
Of the 107 ' unique 80' RHS surface exams, 75-10" NPS welds are considered Exam N/A (less than.375" wall) under 83W83 Rules. The total population of 201 Exam N/A welds (including 6"
NPS welds which were previously temperature and 4
pressure exempt by 80W80 Rules) remain as part of the nonexempt population affecting the determination of the number of examinations for this system, but 3
are themselves not subject for examination under 83W83 Rules.
Inspection h
requirements for the remaining 32 ' unique 80' (12" NPS) welds change to volu-3E metric examination under 83W83 Rules and are appropriately addressed by the 26 q
' unique 83' volumetric and surface examinations.
_=_-
T 4.
The 216 ' unique 80' SIS surface exams is comprised of the following:
60-8" NPS H
and 4-12" NPS welds on lines which are exempt by 83W83 Rules; and 63-8" NPS a'nd sm 89-10" NPS welds which are considered Exam N/A under 83W83 Rules. The latter 8
& 10" NPS welds are part of the tocal population of 269 Exam N/A welds affecting
-g$
the determination of the number of examinations for this system, but are themselves not subject to examination under 83W83 Rules.
Again emphasis is j
shifted to high pressure piping including line sizes down to 2" NPS.
7 e
5.
Of the 69 ' unique 80' SIS volumetric and surface exams, 67-6 & 10" NPS welds are in excess of the number required for 83W83, but it is DLC's intention to still perform a PSI on these welds. The remaining two (2) examinations occur on 12" NPS lines that are exempt by 83W83 Rules.
6.
The Augmented FWS delta does not include 6-2" branch connections, and 24-2" socket welds for which relief from Augmented volumetric examination will be
=
=
requested.
d 7.
The 12 ' unique 80' FWS and MSS volumetric and surface exams occur as follows:
]
two (2) teminal ends in each system on the " break-exclusionaone" wirich~ are a
subject to Augmented volumetric examination in any event; and four (4) terminal 3
ends in each system inside containment. Although examination of these welds z
will be in excess of number of exams required for 83W83, it is DLC's intention y
]
to perform a PSI in these welds.
8.
The Augmented MSS delta does not include 18 miscellaneous branch connections and 68-1.5" & 2" socket welds for which relief from Augmented volumetric ex-J amination will be requested.
-j 9.
Inspection requirements for some of the 24 ' unique 80' SVS surface exams change to volumetric and surface examination under 83W83 Rules for those welds in the as
" break-exclusion zone". All of these welds are subject to Augmented volumetric
=
examination in any case. Remaining exams occur outside this zone on lines which E
become exempt by 83W83 Rules.
j
=
s 3
=
1
=_
G
f;
~
l ATTACHMENT 2 BVPS-2 Break Exclusion Zone Identification (FSAR References) 1.
The FSAR will be amended to define the Break Exclusion Zone as follows:
A..
Subsection 3.6.B.1.1.2:
A subsection will be added as follows:
"Only the main steam and feedwater lines in the Main Steam Valve House and all branch lines up to the first isolation valve in the Main Steam Valve House are considered break exclusion
. zones."
B.
Sub'section :3.6.B.2.1.2.1:
- 1. ' Subitem 2, Paragraphs a and b will be revised as follows:
"2.
Fluid' System Piping in Containment Penetration Areas Breaks are not postulated in the following portions of high
-energy piping, designated as break exclusion zones, a.
Between the containment penetration and the containment isolation valves outside the containment
- b.
Between the containment isolation valve and the first restraint or - group of restraints designed to protect these portions of the piping from breaks outboard of break exclusion zone outside of the containment."
Note:
Paragraph c will be deleted.
2.
Subitem 2, Paragraph vi~ will have the ' following paragraph added:
"The Safety Class 2 portion of break ' excluded piping from the containment penetration up to and including the isolation valve is' designed in accordance with ASME III Subarticle NE-1120. The pipingbetween the ' isolation valve and the next restraint (s) is classified as ' non-nuclear safety and. is. designed -in accordance with ANSI B31.1."
. Note:
The above, for BVPS-2, is considered as an acceptable alternative method of complying with GDC4 by following the guidance of the Standard Review Plan. It meets the require-ments of SRP No. 3.6.2 in that BTP EB 3-1, paragraph B.1.b, states that breaks need not be postulated in those
. portions of Class 22 piping provided they meet the requirements of ASME Code,Section III, Subarticle NE-1120.
i
r.
l
.C. :Secticn 6.6.8 i
This'section will be revised to the following:
q 6.6.8 Augmented In-Service Inspection to Protect Against Postu-lated Piping Failures 1The Augmented _ ISI program provides for examination of high energy piping that - penetrates the primary containment. The piping welds will be examined to Class 2 Examination
' Categories C-F of Table IWC-2500-1.
All nonexempt welds located between the containment wall outside the containment, and the Main Steam Valve House Wall, consisting of only the main steam and feedwater lines in the Main Steam Valve House and all branch lines up to the first isolation valve in the Main Stean Valve House ~are examined using ' volumetric techniques for all circumferen-tial or longitudinal welds.
During each inspection inter-val,- these' welds will be 100 percent. volumetrically examined.
. 11.'
FIGURES PRESENTLY INCLUDED.IN FSAR Figures-3.6B-13a, "Feedwater Lines outside Containment" and 3.6B-14 a,
' " Main Steam Lines Outside Containment," depict the Break Exclusion Zone for main' runs of feedwater and main steam lines.
yy