ML20127A176
| ML20127A176 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 07/31/1985 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Knighton G Office of Nuclear Reactor Regulation |
| References | |
| 2NRC-5-113, NUDOCS 8508050456 | |
| Download: ML20127A176 (8) | |
Text
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'Af Duquesne Lidit 2Ng5;1;3 (412) 923-1960 Nuclear Construction Division Telecopy (412) 787 2629 Robmson Plata. Butiding 2, Suite 210 Pittsburgh, PA 15205 7-31-85 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 Safety-Related Instrument Tubing Program
REFERENCE:
DLC Letter 2NRC-5-072, dated May 17, 1985 Gentlemen:
In the above reference, Duquesne Light Company (DLC) provided the NRC with a detailed description of the proposed safety-related instrument tubing program fo r BVPS-2.
That submittal was discussed with the NRC Mechanical Engineering Branch reviewer, Mr. R. Kirkwood, in telephone conferences on May 30 July 16, July 17, July 18, and July 26, 1985. Attachments 1 through 4 to this letter provide an updated version of the BVPS-2 safety-related instru-ment tubing program which incorporates the minor revisions to the above referenced submittal that we re agreed upon in these conferences.
A summary of these revisions is as follows:
Attachment 1,
Item 19, has been revised to indicate that the proposed program requires all subcontracted work be performed by a Certificate Holder.
Attachment 1,
Item 13, has been revised. to indicate that the proposed program does not require the Piping Contractor's ANI signature on the initial issuance of N6D's.
Attachment 1,
Item 24, has been revised to indicate that the proposed program does not require an Isometric Drawing No. on the storage release form.
At t achme nt 2 has been revised to indicate that, for the proposed program, the SQC visual inspection and DLC's ANI surveillance fo r Safety Class 2 socket and butt welds (Items 3 and 4) and Safety Class 3 socket and butt welds (Items 2 and 5) will be documented via Small Bore Multiple Weld Data Sheets rather than via IR's., Item 4, has been revised to clarify that the hydro-testing fo r the proposed program will undergo approximately 10%
surveillance by DLC s ANI.
It is DLC's unde rs t and ing that, upon receipt of this submittal, the NRC will issue a letter to DLC indicating NRC acceptance of the proposed i
9508050456 G50731 PDR ADOCK 05000412 6
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i United Stctes Nuclear R:rguictory Comualssion Mr. George W. Knighton, Chief l
Safety-Related Instrument Tubing Program Page 2 l
program as it is described in Attachments 1 through 4.
Based on this under-standing, DLC Intends to begin implementing the attached proposed program for BVPS-2 on August 1, 1985.
l or coisment s on the proposed safety-related Any further que stions instrument tubing progran for BVPS-2 may be directed to Mr. J. D. O'Neil of our Licensing Staff at (412) 923-1960.
DUQUESNE licht COMPANY l
By _
J. JJ(Presiden(tf Vice ) arey i
(
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JD0/wjs Attachments cc:
Mr. R. Kirkwood, NRC MEB (w/a)
Mr. B. K. Singh, Project Manager (w/a)
Mr. G. Walton, NRC Resident Inspector (w/a) l l
COMMONWEALTH OF PENNSYLVANIA )
)
SS:
COUNTY OF ALLEGHENY
)
On this,3/o M day of
//I.I, before me, a
(
j Notary Public in and for said Com'enwdalth and County, personally appeared J.
J. Carey, who being duly sworn, deposed and said that (1) he ls Vice l
President of Duquesne Light, (2) he le duly authorized to execute and flle the foregolng Submittal on behalf of said Company, and (3) the statements set i
forth in the Subalttal are true and correct to the best of his knowledge.
1 I
AuSu &
Notary Pu lic MIII4 fl Alf4C REITER, NOTARY FUDLIC 1
ROBINSON TOWruJitP, Atl.s.CHENY COUNTY MY COMMISSI0tt DNRES OCT00ER 20,1986
ATTACHMENT 1 BEAVER VALLEY POWER STATION - UNIT NO. 2 COMPARISON OF PROPOSED SAFETY-RELATED INSTRUMENT TUBING PROCRAM WITH AN ASME III PROCRAM Present Program Proposed Program
( ASME III-19 71/W72 )
(Q.A.,, Category I) 1.
Organizat ion Req uired.
Same as present program.
2.
Training Req uir ed.
Same as present program.
3.
Design Specification Preeaure boundary Same as present program, integrity fo r SSE and dead loads, thermal.
4.
Engineering,
- Design, QA Category I.
Same as present program.
and Document Control approved sup-Same, except no N-s t amp 5.
Procurement Control ASME pliers, CMTR and/or C requi r ed.
of C.
6.
Rece iving, inspection, Physical inspection and Same as present program, ide nt ific a t ion,
stor-review of docu-
- age, and Handling mentation, ANSI storage Control and ma te rial ident ifi-catlon.
7.
Fabrieation and
-Control drawing pac k-No mandatory holdpoints Ins tallation Control age, Site Quality Co n-by DLC 's AN I.
Nonnal QA trol (SQC) a rsi Piping Cat. I Inspection Report Contractor's ANI review is required.
(See of weld data sheets and At t achme nt s 2,
3, and e stabilshed holdpoints, 4).
materlat traceability.
8.
Welding and Brazing ASME III Procedures Same as present program.
Control Wald data package each (See Attachments 2, 3 weld; ASME IX welders.
and 4).
9.
Bolted and other Data sheets for special Same as present program.
Mechanical Joints bolted joint s.
Docu-mene special connect lon torque on Ins pect ion Re po rt.
- 10. He a t Treatment and Not applicable.
Not applicable.
Special Operations and Ropairs
Pcgs 2 Present Program Proposed Program
( ASME III-19 71/W72 )
(Q.A. Category I) i s
- 11. Fab rication and In-SQC.,
Piping Cont r ac-QA Category I isaterial s ta11ation Inspect ion.
tor's AN I, ASME accep-marking or e xc lu s ive tance, mate rial tr ac e-purch ase,,of QA Cat.
I ability req ui r ed of ma te rial s,
control to e ach piece to specific point of use.
Limited material, he at and lot surve il lance by D14's numb e r.
ANI.
(See Item Nos. 24 and 25, and Attachments 2, 3, and 4.)
- 12. Nondestructive. Testing Liquid pe net rant, mag-Same as present progran, netic particle or radio-(See At tachment s 2 and graph for Class 2 & 3.
3.)
- 13. Nonconformances N&D plus data package Same as present program, rev i s ion.
except Piping Contrac-tor's ANI signature not required on initial issuance of N6D.
- 14. Control of Measuring Required.
Same as present program, and Test Equipment
- 15. Aut ho r iz ed Nuclear N-Stamp by Piping Not applic ab le.
Ins pe c t o r and Code Cont rac t o r.
CertifIcatlon
Audit Program eng ineering; DLC arul Piping Contr ac to r for f abrication, ins t al la-tion, and testing.
- 17. DLC Quality Assurance Same as item No. 16.
Same as present program.
armi control Manual and Imple-menting Procedures
- 18. Final Documentation As-built data package.
Acceptance based on SQC/ Piping Contractor's ins pect ion to drawings ANI acceptance.
speci fication and Engi-nearing & Design Coordl-l n ation Report require-monts.
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- 19. Ce rt if ic a t e llo ide r Required.
Same as present program.
l (Subcontracting)
- 20. Pressure Testing 1.2$ eines design pres-1.25 times design pres-sure.
SQC/ Piping sure.
SQC witness.
Contractor's AN I to Surveillance by DLC's witness.
ANI.
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' ' Pcg,3 3 Pressnt Progetm Proposed Program (ASME III-19 71/W72)
(Q.A. Category I)
- 21. SWEC's res pons ibili-Prepare code data forms Not ap plic ab le.
ties when Owner's N-5, N-3.
Piping Con-Designee tractor's AN I witness N-s t amped c ompone nt s.
I
- 22. Exhibits Nume rous forms Ins pect io3 Repo rt s.
XI c ompone nt s.
l
- 24. Storage release Use of fo rm 2 BVF-521 Same as present program, which includes:
except Iso.
No.
not a.
Iso. No.
required.
b.
Description of l
material including l
heat no.
c.
SQC acceptance
- 25. SQC involvement at SQC verify workman Same as present program work location cutting and socket bore to the level determined depth on 7.2.7 IR by SQC. Ins trument ation
- reports, tubing now classified as l
QA Cat.
1, Safety Class 2 or 3.
[
- 26. Fittings and valves Identitles are pe rma-Same as present program.
nently marked.
i
- 27. Material control and Full control.
Not req uired.
weld joint control sheets.
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ATTACHMENT 2 i
BEAVER VALLEY POWER STATION - UNIT NO. 2 PROPOSED EXAMINATION AND TESTINC PROGRAM
- Safety Class 2 Socket and Butt Welds 1.
Perform a 10 0% liquid penetr ant (LP) ins pect ion (docuiie nt via NDE Report).
2.
100% visual ins pec t ion by the Piping Contrac tor prior to release to y
Site Quality control (SQC).
3.
100% SQC visual inspect ion (document via Small Bore Multiple Weld Data Sheet).
4.
10% surveillance by DLC's ANI (document via Small Bore Multiple Weld Data Sheet).
5.
In process surve111ance ins pect ions pe rformed by SQC (document via IR).
6.
100% pressure tested to 1.25 times the design pressure with 100% visual i
inspection of welds (document via Pressure Test Report).
l 7.
Butt welds as per Attachment 4 (document via IR).
Safety Class 3 Socket and Butt Welds 1.
100% visual inspection by the Piping Contractor (document via construc-tion checklist).
Sheet) QC visual ins pect ion (document via Small Bore Multiple Weld Data 100% S 2.
3.
SQC in process inspections (document via IR).
4.
Pressure test to 1.25 times the design pressure (document via Pressure Tes t Report).
5.
10% survelliance by DLC's ANI (document via Small Bore Multiple Weld Data Sheet).
- Seismic Category I Supports l
1.
100% visual inspection of all field welds by the Piping Contractor.
2.
100% SQC visual inspection of all field welds (document via IR).
3 Visual Examination Acceptance Criteria for Pressure-Retaining Welds 1.
All personnel perforising nondes truct ive testing shall be qualified and certified in accordance with SNT-TC-1A.
f 2.
All nondes truc t ive tes ting shall meet the ac cep t ance s tandard s of Paragraph NC-5300 of the applicable ASME III Code Edition.
c ATTACHMENT 3 t
BEAVER VALLEY POWER STATION - UNIT NO. 2 COMPARISON OF PROPOSED 'IUBING EXAMINATION AND TESTING PROGRAM WITH AN ASME III PROGRAM ASME Program Class 2/3 Proposed Exam /Testin'g Program 1.
100% visual inspection 1.
Same as present program.
- 2.
100% LP inspection
- 2.
Same as present program.
3.
Surveillance by Piping C ont rac-3.
Surveillance by DLC's ANI of tor's ANI of in process ac t ivi-approximately 10% of in process t ies activities (includes welding and hydro testing).
4.
Hydro - 100% ins pec t ion by SQC
- 4.
Hydro-100% inspection by SQC at Ag-I 5
L s des gn res u e and Piping Contr ac t o r 's AN,I at broxmatel 1.25 times design pressure LC's ANI.
5.
Surveillance inspection pe r-5.
Same as present program.
fo rmed by SQC, i.e.,
In process Welding, Weld Material Control, Material Control 6.
All ins pect ions performed, with
- 6.
Same as present prog r am, the except ion of Item 5,
are documented in the weld data pac kage s, i.e., Weld Data Sheets 7.
Welde rs and procedures to be 7.
Same as present program.
qualified to ASME IX CNOTE:
For Class 3,
LP is not
- NOTE:
DLC's ANI surve illance of required by ASME III.
actual work and pressure t es t, but not review of docu-me nt at lon.
Uns atis fac to ry conditions noted on DLC's ANI Ins pect ion Repo rt s will be addressed anf resolved via exis t ing Engineering and QA proc ed ur es.
r' i
s o'
t ATTACHMENT 4 i
f BEAVER VALLEY POWER STATION - UNIT NO. 2 1
ADDITIONAL WELDING PROCEDURE QUALIFICATION FOR AUTOMATIC WELDS i
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ASME Code Case N-127 will be applied except that documentation of the activi-l ties will be in accordance with the BVPS-2 proposed program.
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