ML20151T178
| ML20151T178 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 01/30/1986 |
| From: | Rubenstein L Office of Nuclear Reactor Regulation |
| To: | Carey J DUQUESNE LIGHT CO. |
| References | |
| NUDOCS 8602100160 | |
| Download: ML20151T178 (3) | |
Text
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January 30, 1986 Docket No. 50-412 DISTRIBUTION:
' Docket:No750-412 J. Partlow NRC PDR
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P. Tam Mr. J. J. Carey, Vice President Local PDR C. Vogan Duquesne Light Company PAD #2 R/F ACRS (10)
Nuclear Group T. Novak Tech. Branch Post Office Box 4 L. Rubenstein Gray File Shippingport, PA 15077 OELD E. Jordan
Dear Mr. Carey:
B. Grimes
Subject:
Use of ASME Code Case N-32-3 for Certain Class 3 Piping Penetrations for Beaver Valley Power Station Unit No. 2 We have completed our review of your request for authorization to use ASME Code Case N-32-3 for application to certain Section III, Class 3 embedded piping penetrations at the Beaver Valley Power Station, Unit 2 as discussed in the DLC Letter 2NRC-5-066 dated May 6, 1985. The Code Case would be applied to a total of 22 embedded piping penetrations located in the Auxiliary Building, Valve Pits, and Intake Structure. The Code Case would not be applied to the Reactor Contain-ment. penetrations.
Code Case N-32-3 (1541-3) " Hydrostatic Testing of Embedded Class 2 and Class 3 Piping for Section III, Division 1 Construction" was approved for use by the ASME Council on May 15, 1978, and was subsequently endorsed by the NRC staff in Revision 14 of Regulatory Guide 1.84. N-32-3 was annulled on July 1,1979, and was deleted from the list of acceptable Code Cases in Revision 17 of Regulatory Guide 1.84.
N-32-4 superseded N-32-3 on March 16, 1981, and was in effect through its annulment date March 16, 1984. N-32-4 was endorsed by the NRC staff in Revision 19 of Regulatory Guide 1.84.
It is our understanding that installation of the piping penetrations was performed during the period Revision 3 of the Code Case was in effect. The preposed use of Code Case N-32-3 would permit performance of a hydrostatic maintenance of pressure test in lieu of a hydrostatic test in accordance with Paragraph ND-6110 of the Code. Paragraph ND-6110 states, in part, that all joints including welds shall be left uninsulated and exposed for examination during hydrostatic testing. Since the subject piping penetrations had been embedded in concrete prior to performance of a hydrostatic test, usual inspection of the welds could not be performed in accordance with Paragraph ND-6110. DLC has subsequently performed a hydrostatic maintenance of pressure test on the piping penetrations. The penetrations were pressurized to the hydrostatic test pressure and then isolated from the pressurizing source for a period of one hour. All the penetrations successfully demonstrated no pressure drop during the test.
0602100160 060130 PDR ADOCK 05000412 A
PDR t
Mr. J. J. Carey,
DLC concluded that a visual inspection during hydrostatic testing would have no effect on the quality or safety of the penetrations for the following reasons:
i 1.
No portion of the piping penetrations have pressure-retaining welds that are embedded in concrete. The only piping penetration welds that are within the concrete are attachment fillet welds on the outside of the pressure boundary of the penetrations and are not pressure retaining.
The fillet weld sizes are less than the corresponding pipe wall thickness, i
2.
The hydrostatic test pressures for the penetrations are in accordance with Code requirements.
3.
The wall thickness of the penetrations are at a minimum 2.5 times the calculated Code minimum wall thickness.
At our request, DLC has received concurrence from the authorized inspection agencies (Factory Mutual Engineering and the Hartford Steam Boiler Inspection and Insurance Company) for use of Code Case N-32-3 at the Beaver Valley Power Station Unit 2 for the embedded piping penetrations.
We have evaluated the DLC request and concur with the use of Code Case N-32-3 l
for application to the 22 embedded piping penetrations in lieu of a hydro-static test in accordance with Paragraph ND-6110 of the Code. Based on our review, we find that it is impractical within the limitations of accessibilit/
for DLC to meet the ASME Code requirements.
Imposition of those requirement!..
would, in our view, result in hardships or unusual difficulties without a compensating increase in the level of quality or safety. Under these circum-stances, we find the use of Code Case N-32-3 to be acceptable at the Beaver Valley Power Station Unit No. 2 for 22 embedded piping penetrations.
This completes our actions on the subject issue.
If you have any questions, please feel free to contact your project manager, Mr. P. Tam.
Sincerely, Orlainal c!3ncd by L. S. Rubantt:In Lester S. Rubenstein, Director l
PWR Project Directorate #2 Division of PWR Licensing-A Office of Nuclcar Reactor Regulation 3
cc: See next page l0FG :PM: PAD-2
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- NAME :PSTam;b / :L tein DATE :1AJi/86
- 1/29f86 OFFICIAL RECORD COPY
4 Mr.. J. J. Carey Duquesne Light Company Beaver Valley 2 Power Station cc:
Gerald Charnoff, Esq.
Mr. R. E. Martin, Manager, Engineering Jay E. Silberg, Esq.
Beaver Valley Two Project Shaw, Pittman, Potts & Trowbridge Duquesne Light Company 1800 M Street, N.W.
Robinson Plaza Building No. 2 Suite 110 Washington, DC 20036 PA Route 60 Pittsburgh, Pennsylvania 15205 Mr. C. W. Ewing, Quality Assurance Zori Ferkin Manager Assistant Counsel Quality Assurance Department Governor Energy Council Duquesne Light Company 1625 N. Front Street P. O. Box 186 Harrisburg, PA 15105 Shippingport, Pennsylvania 15077 Mr. E. J. Woolever, Vice President Director, Pennsylvania Emergency Special Nuclear Projects Management Agency Duquesne Light Company Room B-151 P.O. Box 4 Transportation & Safety Building Shippingport, Pennsylvania 15077 Harrisburg, Pennsylvania 17120 Mr. T. J. Lex Mr. Thomas Gerusky
-Westinghouse Electric Corporation Bureau of Radiation Protection Power Systems PA Department of Environmental P. O. Box 355 Resources Pittsburgh,~ Pennsylvania 15230 P. O. Box 2063 Harrisburg, Pennsylvania 17120 Mr. P. RaySircar Stone & Webster Engineering Corporation BVPS-2 Records Management Supervisor P. O. Box 2325 Duquesne Light Company Boston, Massachusetts 02107 Post Office Box 4 Shippingport, Pennsylvania 15077 Mr. Glenn Walton U. S. NRC John A. Lee, Esq.
P. O. Box 181 Duquesne Light Company Shippingport, Pennsylvania 15077 1 0xford Centre 301 Grant Street Mr. Thomas E. Murley, Regional Admin.
Pittsburgh, Pennsylvania 15279 U. S. NRC, Region I 631 Park Avenue Mr. Roger Martin, Manager King of Prussia, Pennsylvania 15229 Regulatory Affairs Beaver Valley Two Project Duquesne Light Company P. O. Box 328 Shippingport, Pennsylvania 15077