ML20127M327
| ML20127M327 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 05/17/1985 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Knighton G Office of Nuclear Reactor Regulation |
| References | |
| 2NRC-5-072, 2NRC-5-72, NUDOCS 8505230237 | |
| Download: ML20127M327 (9) | |
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( 2 87 514 (412) 92J-1960 Nuclear Construction Division Telecopy (412) 787-2629 Robinson Plan, Building 2, Suite 21o Pittsburgh, PA 15205 May 17, 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 Tubing Program
REFERENCE:
DLC Letter 2NRC-5-062, dated April 16, 1985 Centlemen:
In the above reference, Duquesne Light Company (DLC) provided you with the BVPS-2 position on Regulatory Cuide 1.151, Rev. O.
This position summarized DLC's proposed program for installation of safety-related instru-ment tubing at BVPS-2.
DLC requested that the NRC provide concurrence to implement the proposed program and any comments by May 3,1985.
In telephone conferences on April 22, April 25, and April 30, 1985, DLC discussed the April 16, 1985, submittal with the NRC Mechanical Engineering Branch (MEB) reviewer, Mr. R. Kirkwood. This submittal, which describes the BVPS-2 safety-related instrument tabing program in detail, addresses the comments provided by Mr. Kirkwood in those conferences and includes the following attachments:
ATTACHMENT 1: Comparison of Proposed Safety-Related Instrument Tubing Program with an ASME III Program ATTACHMENT 2: Proposed Examination and Testing Program ATTACHMENT 3: Comparison of Proposed Tubing Examination and Testing Program with an ASME III Program ATTACHMENT 4: Additional Welding Procedure Qualification for Automatic Welds The proposed program applies to Safety Class 2 and 3 ins trume nt sensing line tubing from downstream of the ASME III socket weld on the root valve up to and including the last valve at the transmitter.
The program applies to tubing that is one-half inch or lesa in diameter. All components of the instrument sensing lines (i.e., tubing, fittings, valves, gages, and suppo rt s), which are under the jurisdiction of the proposed program, are designed to Seistuic Category I requirements and are designated QA Category I.
These components are designed and constructed in accordance with a QA Program that is in compliance with 10CFR50, Appendix B.
Although these components 2
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Unitcd Stctco 'Nucl23r R:gulatory Com:icsion Mr. Gesrg2 W. Knightsn, Chisf
, Safety-Related Ins trument Tubing Program Page 2 are not under ASME Section III jurisdiction, they are designed, fabrica ted,
and ins talled utilizing ASME See t ion III as guidance.
This program is similar-to those which the NRC has recently accepted for other plants.
Any future cases, where DLC would like to apply this program to cert ain instrument tubing that is greate r than one-hal f inch in diameter, will be. identified and a separate request for NRC concurrence will be made at that time.-
In order to begin realizing the cost and schedule benefits associated with this -proposed program - as -soon as pos sib le, DLC requests NRC review of this submittal and concurrence to implement -the program by May 31, 1985. The appropriate; FSAR revisions resulting from this submittal will be made in a future FSAR amendment.
Any questions cr comments on this submittal may be directed to Mr. J.
D. O'Neil of our Licensing staf f at (412) 923-1960.
DUQUESNE LIGHT COMPANY l
By J., J/ /arey" vim President JD0/wjs At tachme nt s cc:
Mr. R. Kirkwood, NRC MEB (w/a)
Mr. B. K. Singh, Project Manager (w/a)
Mr. G. Walton, NRC Resident Inspector (w/a)
SUBjCRIBED AND ORN TO BEFORE ME THIS
/9 DAY OF
/
1985.
[D d h
[th?b Notary Public
/
AULA N.fAtlett NOTART PUGUC ShlPPleGret! 0000, SEAVE8 COUNTY MY C0eul1540s (Itteft SEM.14,1905 Nester. Pessoptresis Aseecation of Notedes f
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Unitcd Stctss Nuclscr R:gulatory Comniosion
- h;r. G;0rgs W. Knighton, Chisif Safety-Related Instrument Tubing Program a
Page 3 COMMONWEALTH UF PENNSYLVANIA )
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COUNTY OF BEAVER
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On this day of
/f[D, before me, a 8
Not ary Public ' in and for said Commonwealth and County, parsonally appeared J.
J. Carey, 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 correct to the best 'of his knowledge.
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Notary Public
$NEllA 5. FAffect, neiAtt PutuC
$NIPPl#GPORT 0000, BEAWE COUNTV NY CONIH$5 tem EIrieft SEPT.16,1905 Nomber. P@asie Asseeistien of Noteries I
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ATTACHMENT - 1 BEAVER VALLEY POWER STATION - UNIT NO. 2 n
COMPARISON OF PROPOSED SAFETY-RELATED INSTRUMENT TUBING PROGRAM y
WITH AN ASME III PROGRAM s
Present Program ~
Proposed Program (ASME III-1971/W72)
(Q A. Category I)
-1
- 0rganization Required.
Same as present program.
- 2.. Training Req uired.
Sate es present program,
- 3.' Desig'n Specification Presaure boundary Same as present program, s
integrity for SSE and dead loads, thermal.
'.4. - - Engineering',
- Design, QA Category I.
Same as present program.
-and Document Control
'5.
Procurement Control ASME approved sup-Same, except no N-stamp pliers, CMTR. and/or C required.
of C.
'6.- ' Receiving, ins pec t ion,
- Physical inspection and Same as present program, identific ation,
stor-review of docu-
- age, and ' Handling mentation, ANSI storage Control; and material ident ifi-ca t ion.
i 7.
Fabrieation and
. Control drawing. pack-No - mandatory holdpoints L
Ins tallation Control age, Site Quality Con-by DLC's ANI.. Normal QA trol (SQC) and Piping Cat. I Inspection Report Contractor's ANI review is required.
. (See of weld data sheets and Attachment s 2,
3, and established holdpoints, 4),
material traceability.
Control.
Weld data package each (See Attachments 2, 3 weld; ASME IX welders, a nd 4 ).
9.
Bolted and other Data sheets for special Same as present program.
Mechanical Joints bolted joint s.
Docu-me nt special connection
[-
t orque on' Ins pect ion Re po rt.
- 10. He a t _ Treatment and Not applic ab le.
Not ap plic ab le.
I Special Operations and Repairs E1
V P' age 2 s "E
Present Program Proposed Program
. (ASME III-19 71/W72)
(Q.A.~ Category I) s.
. 11. Fab rication and In-
- SQC, Piping Contrac-QA Category I material stallation Inspection.
tor's ANI,- ASME accep-marking _ or _ exclusive tance, material tr ac e-purchase of QA Cat. I ability req uired of anterials,
control to e ach piece to speci fic.
point of use.
Limited material.. heat and - lot survelliance by DIE 's number.
ANI.
(See Item Nos.- 24 and 25, and Attachments 2, 3, and 4.)
-12. Nondestructive Testing Llquid penetrant, Same as present program.
magnetic part icle or (See Attachment s 2 and radiograph for Class 2 3.)
& 3.-
- 13. Nonconformances II&D plus data package Same as present program.
revision.
-14. ~ Control ~of. Measuring Required.
Same as present program.
- and Tes t Equipment
- 15. ' Aut ho riz ed Nuclear N-Stamp by Piping Not applicable.
Ins pe c t o r and Code Contrac to r.
Certification
Audit Program engineering; DLC aml -
Piping Contractor for f ab rication, ins t al la-tlon, and testing.
. 17. DLC Quality Assurance Same as Item No. 16.
Same as present program, and 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.
specification and Engi-neering & Design Coordi--
nation Report req uire-ments.
- 19. Ce rt ific a t e -Holder Req uired.
Same as present program (Subcontracting).
but not required.
20.' Pressure Testing-1.25 eimes design pres-1.25 times design pres-aure.
SQC/ Piping sure.
SQC witness.
Contractor's ANI to Surveillance by DLC's witness.
ANI.
L
- Pcg3 3 2,-
-Present Program.
Proposed Program (ASME III-1971/W72)
(Q.A. Category I)-
- 21. SWEC's:
res potis ibili-Prepare code data forms Not applic ab le,
ties. when Owner's N-5, N-3.
. Piping Con-Designee trac to r's ANI witness N-stasped components.
- 22. Exhibits
. Numerous forms Ins pe ct ion Repo rt s.
- 23. Ope rations under ASME
-Governs repair of ASME Not applicable.
XI c omponent s.
- 24. Storage rele.ase Usc of form 2BVF-521 Same as present program.
which includes:
a.
Iso. No.
b.
Description of mate rial including heat no.
c.
SQC acceptance
- 25. 'sQC involvement at SQC ve ri fy workman Same as present. program work location cutting and socket bore to the level de termined depth on 7.2.7 IR by SQC. Ins trume nt ation reports.
tubing now class,ified as QA Cat.
1, Safety Class 2 or 3.
- 26. - Fittings and valves Identities are pe rma- -
Same as present program, nently marked.
- 27. Material. control and Full control.
Noc required,
weld jo' int control
. sheets.
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R ATTACHMENT 2 BEAVER VALLEY POWER STATION - UNIT NO. 2 PROPOSED EXAMINATION AND TESTING PROGRAM
~* Safety Class 2 Socket and Butt Welds 1.
Perform -a 100% liquid penetr ant (LP) ins pect ion (document vis NDE Report).
2.
100% t isuti, ins pection by, the Piping Contrac tor prior to release to Site Quality Control- (SQC).
3.
100% SQC visual inspection (document via IR).
4.
10% surveillance by DLC's ANI.
5.
- In process surveillance ins pect ions performed by SqC (document via IR).
6.
100% pressure tested to 1.25 times the design pressure with 100% visual inspection of welds (document via Pressure Test Report).
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).
l 2.
'100% SQC visual inspection (document via~ IR).
3.
SQC in process inspections (document via IR).
4.
Pressure test to 1.25 times the design pressure (document via Pressure Test Report).
5.
10% Surveillance by DLC's ANI.
l Seismic Category I Supports 1.
100% visual inspection of all field welds by the Piping Contractor.
2.
100% SQC visual inspection of all field welds (document via IR).
- Visual Examination Acceptance Criteria for Pressure-Retaining Welds 1.
All personnel performing nondestructive testing shall be qualified and certified in accordance with SNT-TC-1A.
2 All ' nondestructive tes t ing shall meet the ac cept ance s tandards of Paragraph NC-5300 of the applicable ASME III Code Edition, L
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7 ATTACHMENT 3 BEAVER VALLEY POWER STATION - UNIT NO. 2 COMPARISON OF PROPOSED' TUBING EXAMINATION AND TESTING PROGRAM WITH-AN ASME III PROGRAM f
ASME Program Class 2/3 Proposed Exam / Testing Program l.'. 100% visual. inspection -
1.
Same as present-program.-
- 2 ~ 100% LP inspection
- 2.
Same as present pr ogram.
L 3'.
. Surveillance by Piping Contrac-3.
Surveillance by DIf'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% inspec tion by SQC
- 4.
Hydro-100% inspection by 'SQC at and Piping Contractor's ANI at 1.25 eines design pressure.
1.25 times design pressure Surveillance by DLC's ANI.
5.
Surveillance inspection pe r-5.
Same as present program.
formed by SQC, i.e., - In proces s
' Welding, - Weld Material Control,
.-Material Control 6.
All' inspections pe rformed, with
- 6.
.Same as present program.
the. exception of Item 5,
are documented in the weld ' data
_ packages,
i.e., Weld Data Sheets 7.
Welde rs 'and ' procedures. to be 7.
Same.as present program.
qualified to ASME IX
- NOTE:
For Class-3, LP is not
- N OTE :
DLC's ANI surveillance of required by ASME III.
actual work 'and pressure t es t, but not review of docu-me nt at ion.
. Uns atis fac to ry conditions noted on DLC's ANI Ins pect ion Report s will.be addres sed armi. resolved via existing Engineering and QA proc ed ures.
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--BEAVER VALLEY POWER STATION - UNIT NO. 2 ADDITIONAL WELDItG PROCEDURE QUALIFICATION FOR AUTOMATIC WELDS ASME Code Case N-127-will be applied except that documentation of the activi-ties will be in accordance with the BVPS-2 proposed program.
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