ML20115G168

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Forwards Evaluation of safety-related Instrument Sensing Lines Utilized at Facility,Including Consideration of Guidance of Reg Guide 1.151.Position Will Be Incorporated Into Future FSAR Amend.Comments Requested by 850503
ML20115G168
Person / Time
Site: Beaver Valley
Issue date: 04/16/1985
From: Carey J
DUQUESNE LIGHT CO.
To: Knighton G
Office of Nuclear Reactor Regulation
References
RTR-REGGD-01.151, RTR-REGGD-1.151 2NRC-5-062, 2NRC-5-62, NUDOCS 8504220131
Download: ML20115G168 (4)


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412 787 5 1 2)923-!960 Nuclear Construction Division Robinson Plaza, Building 2, Suite 210 Telecopy (412) 787-2629 Pittsburgh, PA 15205 Apr11 16, 1985 United States Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:

Mr. George W. Knighton, Chief Licensing Branch 3 Of fice of Nuclear Reactor Regulation

SUBJECT:

Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 Safety-Related Instrument Sensing Lines Gentlemen:

9 Duquesne Light Company (DLC) has completed an intensive review and evaluation of safety-related instrument sensing lines utilized at BVPS-2, including consideration of the guidance of Regulatory Guide 1.151, Revision 0.

The results of this evaluation are reflected in the attached BVPS-2 position on this regulatory guide.

This position will be incorporated into FSAR Table 1.8-1 in a future FSAR amendment.

The program for installation of safety-related ins trume nt sensing lines, described in the attached pos it ion, will be beneficial from both a cost and schedule standpoint, while having no adverse ef fects on the quality of instrument sensing line installation or on plant safety.

It is DLC's understanding that the NRC has reviewed and concurred with similar programs for instrument sensing lines that have been established at other plants.

In orde r to provide for optimization of these cost and schedule benefits through expeditious impleme nt at ion of this program, DLC requests that the NRC review the attached information and provide concurrence and any comments by May 3, 1985.

Any questions or comments on this submittal may be directed to Mr.

J. D. O'Neil of our Licensing staff at (412) 923-1960.

DUQUESNE LIGHT COMPANY By y-l

.l /

Jg J. Carey

/ v Vice President JD0/wjs Attachment cc:

Mr. R. J. Bosnak, NRC MEB Chief (w/a)

Mr. B. K. Singh, Project Manager (w/a)

Mr. G. Walton, NRC Resident Inspector (w/a)

SUBSCRIBED AND Sy0RN Tp BEFORE ME THIS g DAY OF

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1985, ib 1 lE<_

Notary Public 0504220 h04 oo ANITA ELAINE REITER, NOTARY PUBUC PD ROBINSON TOWNSHIP, ALLEGHENY COUNTY PDB b

MY COMMISSION EXPIRES OCTOBER 20,1986 8ool m

- United Stetso Nuclesr R2gulctory Ccunniocion Mr. Gacrg2 W. Knighton, Chisf Safety-Related Instrument Sensing Lines Page 2 COMMONWEALTH OF PENNSYLVANIA )

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-SS:

COUNTY OF ALLEGHENY

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On this

/d day of

/((I,'beforeme,a Notary Public in -and for said Com nwealth and County, personally appeared E.

J. Woolever, who being duly sworn,' feposed 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 correct to the best cf his knowledge.

1 Notary Public ANITA ELAINE REITER, NOTARY PUBUC ROBINSON TOWNSHIP, ALLEGHENY COUNTY MY COMMISSION EXPIRES OCTOBER 20,1986

e-BEAVER VALLEY POWER STATION - UNIT NO. 2 Position on Regulatory Guide 1.151, Revision 0, dated July 1983 (" Instrument Sensing Lines")

The design and installation criteria for safety-related instr v nt sensing lines at BVPS-2 meet the intent of this Regulatory Guide with tne following alternatives and clarifications provided for Regulatory Positions C.2 and C.3:

Class breaks are established in accordance with ISA-S67.02 as modified by this Regulatory Guide with the following alt erna-tives and clarifications:

1.

All components (i.e., tubing, fittings, valves, and gages) i of the instrument sensing lines are designed to Seismic Category I requirements and are designated QA Category I.

These casponents are not under ASME Section III jurisdic-tion, but they are designed,. fabricated, and installed utilizing ASME Section III as guidance.

The ins trume nt sensing lines are identified as Nuclear Safety-Related in lieu of Safety Class 2 or Safety Class 3.

2.

All documentation and material traceability for the instru-ment sensing. line components is maintained for the procure-ment phase of these components. Full quality control on weld rsd traceability is maintained through weld data sheets.

3.

Since the instrument sensing line compo nent s,- including N-s tanped valves, are identified as Nuclear Safety-Related in lieu of being under ASME Section III jurisdiction, these components are not under ANI jurisdiction nor under the eventual jurisdiction of ASME Section XI.

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e. Unitsd Stetso Nuc1scr Ragulctory Commiasion Mr. G2crga W. Knighton, Chief Safety-Related Instrument Sensing Lines Page 3 JD0/wjs NR/NRC/SRISL Attachment bec:

J. J. Carey

- w/ attachment W. T. Wardzinski

- w/ attachment E. J. Woolever

- w/ attachment R. E. Dougher.

- w/ attachment C. E. Ewing

-- w/ attachment T. D. Jones

- w/ attachment J. A. Hultz

- w/ attachment E. F. Kurtz, Jr.

- w/ attachment J. H. Latshaw

- w/ attachment R. E. Martin

- w/ attachment T. P. Noonan

- w/ attachment J. A. Rocco

- w/ attachment R. J. Swiderski

- w/ attachment L. E. Arch

- w/ attachment G. L. Beatty

- w/ attachment E. T. Eilmann

- w/ attachment K. M. Holcomb'

- w/ attachment J. Lee, Esq.

- w/ attachment S. L. Pernick, Jr.

- w/ attachment J. J. Szy Slow Ski

- w/ attachment M. A. Zaki

- w/ attachment T. J. Zog1mann

- w/ attachment A. A. Dasenbrock

- w/ attachment J. R. Houghton

- w/ attachment D. E. Burke (CEI)

- w/ attachment R. G. Schuerger (CEI) - w/ attachment B. M. Miller (2) (OEC) - w/ attachment J. Silberg (SPPT)

- w/ attachment D.. Chamberlain (S&W)

- w/ attachment P. RaySircar (S&W)(5) - w/ attachment (3)

T. J. Lex (W)

- w/ attachment i

B. Lorenz (W)

- w/ attachment DLC/ EPM

- w/ attachment NCD File

- w/ attachment l

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