ML20207S027

Requests NRC Acceptance of Inclusion of Process Tubing to safety-related Instrument Tubing Program W/Modified Program Identified as safety-related Instrument & Process Tubing Program,Per 870129 Telcon.Asme III Program Comparison Encl

ML20207S027
Person / Time
Site:	Beaver Valley
Issue date:	03/12/1987
From:	Carey J DUQUESNE LIGHT CO.
To:	Tam P NRC
References
2NRC-7-049, 2NRC-7-49, TAC-64978, NUDOCS 8703180443
Download: ML20207S027 (8)

Text

t

[

'Af Beaver Valley No. 2 Unit Project Organization ( 2 6415200 Telecopy (412) 64}5200 Ext.160

[,$,Gg,8"$$h"' March 12, 1987 Shippingport. PA 15077 United States Nuclear Reguitory Commission ATTN: Mr. Peter Tam Mail Stop 340 Washington, DC 20555

SUBJECT:

Beaver Valley Power Station Unit No. 2 Docket No. 50-412 Addition of Process Tubing in Safety-Related Instrument Tubing Program

REFERENCES:

1) Letter from G. W. Knighton (NRC) to J. J. Carey (DLC) " Safe-ty-Related Instrument Tubing Program for Beaver Valley Power Station Unit No. 2 dated Septenber 9,1985.

2) Letter 2NRC-5-113 from J. J. Carey (DLC) to G. W. Knighton (NRC) dated July 31, 1985.

Gentlemen:

During a January 29, 1987 telecon with the NRC staff concerning safety-related, Class 2 process tubing inside containment, it was tentatively agreed that such process tubing could be included with DLC's existing " Safety-Related Instrument Tubing Program" if the following conditions were met:

1. The same requirements for safety-class instrument tubing program were applied to process tuoing.

2. Since such tubing is still safety class 2, inside containment, it is still considered Reactor Coolant Boundary.

This tubing is seismically and ASME 111 designed, and is included in the ASME 111 Stress Reconciliation Progran, although (like safety-related instru-ment tubing) is not ASME Code stanped.

Therefore, DLC requests NRC acceptance of inclusion of process tubing to the " Safety Related Instrument Tubing Progran" with the modified progran iden-tified as " Safety Related Instrument and Process Tubing Progran". Attachment 1, Revision 1 is the same as that progran submitted with the addition of "and process" to the title.

DUQUESNE LIGHT COMPANY 4

By W. 4,/ Carey Senior Vice President

\

0703180443 870312 )\

PDR ADOCK 05000412 A PDR

F 4

~ United States Nuclera Regulatory Commission Mr. George W. Knighton, Chief Addition of Process Tubing . . . . . Instrument Tubing Program Page 2 JJS/ijr NR/JJS/ INST /PRG Attachment AR/NAR cc: Mr. P. Tam, Project Manager - w/ attachment Mr. J. Beall, NRC Sr. Resident inspector - w/ attachment Ms. A. Asars, NRC Resident inspector - w/ attachment INP0 Records Center - w/ attachment NRC Document Control Desk- - w/ attachment i

l 3

i l-i

ATTACHMENT 1

- BEAVER VALLEY POWER STATION - UNIT NO. 2

- COMPARISON OF- PROPOSED SAFETY-RELATED INSTRUMENT AND PROCESS TUBING PROGRAM WITH AN ASME 111 PROGRAM

_ (ASME III-1971/W72) (Q.A.,, Category I)

1. Organisation Req uired . Same as present program.

2. Training Req uired . Same as present program.

3. Design Specification Pressure 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

5. Procurement Control ASME -

approved sup- Same, except no N-stamp pliers, QfrR and/or C requir ed .

of C.

6. Rece iving , ins pec t io'n , Physical ins pection and Same as present program.

ide nt ific a tion, stor- review of doeu-age, and Handling mentation, ANSI storage Control and mate rial ident ifi-ca t ion.

7. Fabrieation and Control drawing pac k- No mandatory holdpoints Ins callation 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 e stablished holdpoints, 4).

material traceability.

8. Welding and Brasing ASME III Procedures -

Same as present program.

Control Weld 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 bolt ed joints. Docu-mene special connection to rque on Ins pect ion Re po rt ,

b

10. He a t Treatment and Not applicab le . Not applicable.

Special Operations and l Repairs I

REV. 1 i 2/27/87 l

Page 2 Present Program Proposed Program

( ASME III-19 71/W72 ) (Q.A. Category I)

11. Fab ric ation and In- SQC,, Piping Contr ac- QA Category I material s ta11ation Inspection. tor's AN I, ASME accep- marking or exc lu s ive tance, mate rial tr ac e- purch ase of QA Cat. I ability req uir ed of ma te ri al s',' control to

- e ach piece to specific point of use. Limited ma terial , he at and lot surveillance by DIf's number. ANI. (See Item Nos. 24 and 25, and Attachments 2, 3, and 4.)

12. Nondestructive Testing Liquid penet rant , mag- Same as present progr an.

netic particle or radio- (See Attachments 2 and ~

graph for Class 2 & 3. 3.)

13. Nonconformances N6D plus data package Same as present program, revision, except. Piping Contrac-tor's ANI signature not required on initial issuance of N&D.

l

14. Control of Measuring Required. Same as present program, and Test Equipment

15. Aut ho r iz ed Nuclear N-Stamp by Piping Not ap plic ab le .

Ins pec to r and Code Contrac to r .

Ce rtificat ion .

16. Quality Assurance SWEC ASME QA Manual for Same as present program.

Audit Program engineering; DLC and Piping Contr actor for f ab rie a t ion , ins e al la-tion, 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. speci fica tion and Engi-neering & Design Coordi-n atio n Report req uire-ments.

19. Ce rt if ic a te Holder Req uired . Same as present program.

(Subcontracting)

20. Pres sure Testing 1.25 times design pres- 1.25 times design pres-sure. SQC/ Piping sure. SQC witness.

Contractor's AN I to Surve illance by DLC's witness. ANI.

Page 3 Present Program Proposed Program

. . (ASME III-19 71/W72) (Q A. Category I) t

21. SWEC's res pons ibili- Prepare code data forms Not ap plic ab le .

tles when Owner's N-5 , N-3. Piping Con-Designee tractor's ANI witness N-s t amped c ompone nt s .

I 22. Exhibits Numerous forms Ins pe ct io'n Re po r' t s .

23. Ope rations unde r ASME Coverns repair of ASME Not ap plic ab le .

XI c omponent s.

24. Storage release Use of form 2 BVF-521 Same as present program, which includes: except Iso. No. not

a. Iso. No. required.

b. Description of material 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 trumentation reports. tubing now classified as QA Cat. 1, Safety Class 2 or 3.

26. Fittings and valves Identit ies are pe rma- Same as present program.

nently marked.

27. Material control and Full control. Not required .

weld joint control sheets.

~

t

• ATTACHMENT 2

' BEAVER VALLEY POWER STATION - UNIT NO. 2 PROPOSED EXAMINATION AND TESTING PROGRAM Safety Class 2 Socket and Butt Welds

1. Perform a 10 0% liquid penetrant (LP) ins pect ion (docudent via NDE Report).

2. 100% visual ins pec t ion by the Piping Contrac t or prior to release to Site Quality Control (SQC). .

3. 100% SQC visual ins pection (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 surve illance ins pect ions perfo rmed 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).

2. 100% SQC visual inspect ion (document via Small Bcre Multiple Weld Data Sheet)

3. SQC in process inspections (document via IR).

i 4. Pressure test to 1.25 times the design pressure (document via Pressure Test Report).

5. 10% survelliance by DLC's ANI (document via Small Bore Multiple Weld Data Sheet).

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 nondes truct ive testing shall meet the ac cep t ance standards of Paragraph NC-5300 of the applicable ASME III Code Edition.

ATTACHMENT 3-8 4 BEAVER VALLEY POWER STATION - UNIT NO. 2 COMPARISON OF PROPOSED TUBING 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'ntrac- 3. Surveillance by D14's ANI of tor's ANI of in process ac t ivi- approximately 10% of in process ties activities (includes welding and hydro testing).

4. Hydro - 100% ins pection by SQC **4. Hydro-100% inspection by SQC at and Piping Contrac tor's AN,I at 1.25 times design pres,sure. A{y roximatel 10 survet11ance 1.25 times design pressure LC's ANI.y

5. Surveillance inspection per- 5. Same as present program.

formed by SQC, i.e., In process Welding, Weld Material Control, Material Control

6. All inspections pe rf ormed , with **6. Same as present program, the except ion 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 tory conditions noted on DLC's ANI Ins pect ion Reports will be addres sed and resolved via existing Engineering and QA procedures.

r- .

-O

, ATTACHMENT 4

,e ,

• a BEAVER VALLEY POWER STATION - UNIT NO. 2 ADDITIONAL WELDING PROCEDURE QUALIFICATION FOR AUTOMATIC WELDS 4

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.

d I

4 4

l l

e a

I l

[