ML20137G465

Relief Request BV3-IWA-1,Rev 0 to Insulation Removal for Class 1 & 2 Bolted Connections Located Inside Containment

ML20137G465
Person / Time
Site:	Beaver Valley
Issue date:	03/12/1997
From:	DUQUESNE LIGHT CO.
To:
Shared Package
ML20137G377	List: ML20137G371 ML20137G408 ML20137G422 ML20137G435 ML20137G444 ML20137G455 ML20137G459 ML20137G465 ML20137G479
References
PROC-970312-06, PROC-970312-6, NUDOCS 9704010402
Download: ML20137G465 (2)

Text

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i PRESSURE TESTING PROGRAM I AT BVPS UNIT #1, FOR THE THIRD TEN YEAR INTERVAL AND l BVP2 UNIT #2, FOR THE SECOND TEN-YEAR INTERVAL RELIEF REQUEST BV3-IWA-1, REV. O

SUBJECT:

Insulation Removal for Class 1 and 2 bolted connections located inside containment I i

Prepared by: -Pb b < DV4}

Supemstr, Inspection and Standards Date: #!do[f f i

Reviewed by: h su J L EA11 Date: 3- Il-97 Director, Nuclear Analysis and Ins ion i Resiewed by: 3Y - CSC - b- 97 Date: 3//J/f 7 '

OSC Meeting No.

Reviewed by: N M V64 d. $'l I Date: d/X [f 7 ORC Meetinh No.

Approval by: / w ,e c Date: 3-/289 Div'. VP, Nuclear Operations / Pla'nt Manager 9704010402 970325 PDR ADOCK 05000334 G PDR A

o

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DUQUESNE LIGHT COMPANY Beaver Valley Power Station Unit Nos. I and 2 RELIEF REOUEST NO. BV3 IWA-1 Rev. O COMPONENT Class I and 2 bolted connections in systems borated for the purpose of controlling reactisity located inside the reactor containment building.

ASME SECTION XI REOUIREMENT (89 Edition)

Examination Categories B P of Table IWB-2500-1 and C-H of Table IWC-2500 1 require visual, VT-2 examination of all pressure retaining components during pressure testing. IWA 5242(a) requires insulation removal from bolted connections for the visual VT 2 examination in systems borated for the purpose of controlling reactivity.

BASIS OF RELIEF in accordance with 10CFR50.55a(a)(3)(ii) reliefis requested from ASME Section XI,1989 Edition, IWA-5242(a).

IWA-5242(a) requires that for systems borated for the purpose of controlling reactivity, insulation shall be removed from pressure retaining bolting for visual examination VT 2. Compliance with this Code requirement would result in hardship and unusual difficulty without a compensating increase in the level of quality and safety, based on the following:

1. Code Class I and 2 systems borated for the purpose of controlling reactivity are large systems covering many areas and elevations of the reactor containment building. Many of the bolted connections are located in areas difYicult to access and have significant radiation levels. Scaffolding is required to access the majority of the bolted connections. As required by IWB-5221, the System Leakage Test is conducted at normal operating pressure and temperature. The visual, VT 2 examination is performed prior to plant startup at mode 3. This examination is a critical path activity snd normally has a short duration of approximately 4 to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. To delay reactor criticality due to installation ofinsulation and disassembly and removal of scaffolding under sub-atmospheric conditions is an undue burden without a compensating increase in the level of quality and safety.

Outage durations and costs will be significantly increased and personnel safety will be impacted under these operating conditions.

2. Leakage of borated water will leave a residue of boron. Boron residue is evidence of leakage and inconsequential to whether the system piping is under pressure or not at the time of the visual VT 2 i examination. l 1

PROPOSED ALTERNATIVE EXAMINATION A visual. VT-2 examination will be performed during the system pressure tests ofIWB 5000 and IWC-5000 with the insulation installed. In addition, insulation will be removed from all Class 1 and 2 bolted connections located inside the reactor containment building in systems borated for the purposes of controlling reactivity, at least once per inspection period during an outage and a visual VT 2 examination shall be performed for evidence ofleakage (residue of boron) regardless if system pressure exists or not. l Duquesne Light requests NRC approval of the proposed alternative requirements for VT-2 visual examination of Class I and 2 insulated pressure retaining bolted connections in lieu of those ofIWA-5242(a). NRC approval is requested in a time frame that will support implementation of the alternative requirements for the Unit I twelfth refueling outage currently scheduled to begin in September of 1997. Unit I twelfth refueling outage will be the first outage of the third ten year interval at Beaver Valley Power Station Unit No.1. The second ten year interval at Beaver Valley Power Station Unit No. 2 will begin November 17,1997, m