Forwards for review proposed Rev 7 to Topical Rept TVA ... · system was circulated by a centrifugal pump and metered by a calibrated elbow meter located just downstream from the

A27 830711 015 400 Chestnut Street Tower II

July 11, 1983

U.S. Nuclear Regulatory Commission Region II Attn: Mr. James P. O'Reilly, Regional Administrator 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303

Dear Mr. O'Reilly:

Fnclosed for your review are two copies of a proposed.Revision 7 to TVA's Topical Report, TVA-TR75-1A, "Quality Assurance Program Description for Design, Construction, and Operation of TVA Nuclear Power Plants."

Proposed Revision 7 to TVA-TR75-1A is the submittal required by the January 10, 1983 change to 10 CFR 50.54 and 50.55. In my letter to you dated June 9, 1083, the submittal date of proposed Revision 7 was delayed', and you were informed that the changes in T'A-TR75-1A would be sufficiently extensive as to require additional time to meet the requirements of 10 CPR 50.54 and 50.55. R. C. Lewis' letter to me dated June 28, 1983 accepted the delay in the submittal of Revision 7 until August 15, 1983.

Proposed Revision 7 is a major change to the TVA Oality Assurance Program description. The topical has been reformatted to be consistent with the description of TVA's integrated quality assurance program for design, construction, and operation. The major format changes have been the consolidation of all organizational descriptions into section 17.0 and the relocation of all figures and tables to the appendices. Additionally, the organizational descriptions have been updated to provide a consistent level of detail for the various TVA organizational units, and portions of the section 17.1 and 17.2 program descriptions have been revised to provide a more accurate description of our current program and practices. This revision contains a description of the TVA Office of Quality Assurance (OA) and includes in table 17.A-5 a new list of the procedures by which OQA will perform its assigned activities. These OQA procedures are to supersede those utilized by previous quality assurance units.

TVA has evaluated the program changes and found that these program changes do not reduce the comitments described in Revision 6 of TVA-7R75 1A, Pxcept for a change in a comitment to ANSI H45.2.1 (see table 17.D-1). My letter to Ms. 2. Adensam dated April 18, 1983 requested approval of a reduction in the commitment to an ANSI N45.2.1 requirement and contained information to justify the reduction.

8712300250 5 2438 PDR ADOCK 05 PDR P

-2-

Mr. James P. O'Reilly

If you have any questions concerning this D. L. Lambert at FTS 858-2733.

July 11, 1983

matter, please get in touch with

Very truly yours,

TENNESSEE VALLEY AUTHORITY

L. H. Mills, Manager Nuclear Licensing

DLL:CAL Enclosure cc (Enclosure):

Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Director of Office of Inspection and Enforcement

ATTN: Mr. Walter P. Raass, Deputy Branch Chief Quality Assurance Branch

U.S. Nuclear Regulatory Commission Washington, D.C. 20555

cc: ARMS, 640 CST2-C (Retained in 400 CST2-C) J. W. Anderson, M155G MIB-K (Enclosure) . H. N. Culver, 249A HBB-K E. J. Ford, NRC Resident Inspector, Sequoyah (Enclosure) H. J. Green, 1750 CST2-C T. Heatherly, NRC Resident Inspector, Watts Bar (Enclosure) A. T. Mullins, 403 KB-C G. Paulk, NRC Resident Inspector, Browns Ferry (Enclosure) J. A. Raulston, W10C126 C-K H. S. Sanger, Jr., E11B33 C-K F. A. Szczepanski, 417 UBB-C J. D. Wilcox, NRC Resident Inspector, Bellefonte (Enclosure) J. L. Williams, 1000 CUBB-C (ATTN: R. H. Sunderland) (Enclosure)

Z..

........ ,.o....

* EF"7tE)X CE 7

A27 830831 00

400 Chestnut Street Tower I

August ?1, 1981

Director of nuclear Reactor Regulation Attention:_ Ms. 7. Adensam, Chief

Licensing Branch No.-$ Division of LicensinK


Dear Ms. Adensam:

In the Matter of the Application of ) Docket Nos. 10-418 Tennessee Valley Authority ) - 50-434

In our letter of April 18, 1983, we provided you with information in support of TVA's request for an exemption, in part, from ANSI N45.2.1 for Bellefonte Nuclear Plant. At this time we are submitting additional information to aid In your determination. Enolosed is a copy of a report evaluating the effeotiveness of sidestream samplinq, (Enolosure 1). Enolosure 2 is a copy of an information package developed by TVA to support a reduction in TVA's ANSI N45.2.1 comitment. Copies of MYA's correspondence with the American Society of Mechanical Engineers, Nuclear Quality Assurance Committee, over the exemption issue, have been included as

-Enclosure 3.

In order to prevent any further construction delays and/or additional TVA expense, we request an expedited MBC review of this exemption request.

If you have any questions concerning this matter, please get in touoh with Bill Vatt4-rs at PTS 858-2691.

Very truly yours,

TENPESSF VALLEY AUTHORITY

L. M. Mills, Manager Nuclear Licensing

'worn 'to n subsor bed before me t Als dav of 13

0 ota ry Pub !lio t, Commission Expires

Enclosures (3) cc: U.S. Nuclear Regulatory Commission (Enclosures)

Region TI Attn: Mr. James P. O'Reilly Administrator 101 Mrietta Street. qW, Suite 2900 Atlanta, Georgia 30303

-2-

U.S. Nuclear Regulatory Commission August 31, 1983

TW:LHB cc (Enclosures).

ARMS, 640 CST2-C J. W. Anderson, M155G MIB-K H. N. Culver, 249A HBB-K H. J. Green, 1750 CST2-C R. L. Lumpkin, 401 UBB-C (2) J. A. Raulston, W10C126 C-K H. S. Sanger, Jr., E11B33 C-K F. A. Szczepanski, 220 401B-C J. D. Wilcox, Bellefonte-NRC

COORDINATED: EN DES/SLove, OA/JCrittenden

-. 1

FL

If Ii'

ALL NUCLEAR PLANTS

EVALUATION OF THE EFFECTIVENESS

OF SIDESTREAM SAMPLING

I.

Knxil,

ense

TENNESSEE VALLEY AUTHORITY DIVISION OF CONSTRUCTION SINGLETON MATERIALS ENGINEERING LABORATORY

4:,

ENCLOSURE 1

N I . .

TVA 64 (03*045)

UNITED STATES GOVERNMENT

fMemorandum

C. A. Chandley W7C126 C-K Frank Van Mete

DATE : July 18, 1983

SBET ALL NUCLEAR PL KSUBJECT:

As requested i was constructe Objectives of parameters and included contai report shows i sidestream sam contaminant wi exponentially

-I

3 78 TENNESSEE VALLEY AO ITY

, Chief, Mechanical Engineering Support Branch, (2) r, Chief, Construction Services Branch, 500 SPT-K

ANTS - EVALUATION OF THE EFFECTIVENESS OF SIDESTREAM SAMPLING

n MEB 830201 011, a proof flush sidestream sampling apparatus I and tested at the TVA Engineering Laboratory at Norris. the testing program were to determine sidestream sampling to quantify limits of detectability. Test variables minants, pipe sizes, and flush velocities. The attached r a contaminant is suspended in water flowing past a pler of the type described in TVA G-39, section 8.5.3.2, the Ll be sampled. The amount of contaminant sampled is an decreasing function of sampling time.

Original signed by Frank Van Meter

Frank Van Meter

WHC:LES:ASY Attachments cc (Attachments):

W. R. Brown, 102 ESTA-K W. H. Childres, SME-K E. Ely Driver, LAB-N (2) G. R. Hall, 6204 MIB-K R. M. Hodges, 1117 IBM-K R. M. Pierce, 104 ESTA-K M. N. Sprouse, W11A9 C-K J. C. Standifer, 204 GB-K J. P. Vineyard, 304 ESTC-K MEDS, W5B63 C-K

Principally prepared by L. E. Smith, extension 2771, and Svein Vigander, extension 4460.

Buy U.S. Savings Bonds Repularly on the Payroll Savings Plan

A13188.1

ABSTRACT

This report describes the test facility, procedures, data

reduction, and results of physical tests performed on a laboratory pipe

loop constructed to evaluate the performance efficiency of sidestream

sampling as a measure of pipe cleanliness. Tests were made using various

pipe sizes, flow rates, and contaminants, which included metal filings,

pieces of tape, and pieces of glued purge paper.

It is shown for all pipe sizes, flows, and contaminants, that the

concentration of contaminants in the side stream generally conformed to the

exponential equation: Ct = C0h exp (-kt) where Ct is the sidestream

contaminant concentration, CO is the initial concentration of contaminant

in the piping system, h is the fraction of contaminant suspended in the

flush flow, k is proportional to the ratio of sampling discharge rate to

the total piping system volume, and t is time. The efficiency of

sidestream sampling was characterized by the sampling time needed to

collect 95 percent of all the contaminants that would be collected. The

data reveal the time required to sample 95 percent of the material

collected was about 15 min for metal filings and 60 min for duct tape. The

results also show the amount of each contaminant trapped in the pipe system

and therefore not collected by sidestream sampling. This number is

characteristic of each particular pipe loop.

2

. INTRODUCTION

Fluid handling systems at Bellefonte Nuclear Plant are cleaned by

procedures described in TVA General Construction Specification G-39.

System contaminants are typically small-metal particles, duct tape, and

glue impregnated purge paper. The amount of contaminants in a system.is

measured during proof flushing through the use of sidestream sampling and

filtering of flush water. The sidestream sampler is typically a 90-degree

pipe tee with the diameter smaller than the process pipe.

At the request of the Mechanical Engineering Support Branch,'-the

Singleton Materials Engineering Laboratory with support from the Water

System Development Branch constructed a test system with 6- and 10-in, test

sections and a 2-in. sidestream sampler. The ability of the sidestream

sampler to collect contaminants varying in size, shape, and weight was

measured for different flush flow velocities. These tests were designed to

evaluate the characteristics of the sidestream sampling technique in terms

of the length of time needed to ensure complete sampling. Known amounts of

contaminants were introduced into the system and recirculated in a pipe

loop while a fraction of the contaminants was sampled in a sidestream

discharge. The amount of contaminant sampled naturally depends upon the

fraction in suspension and the fraction lodged in various kinds of traps in

the piping system. For contaminants heavier than water, a trap would

consist of abrupt changes in the pipe bottom geometry, such as the side

stream sampling tee, the bottom of valve and pump housings, and dead end

downward tees. Contaminants would be moved with the flush water as

suspended particles in vertical pipe runs and suspended or bouncing along

the bottom in horizontal pipe runs. The fraction of contaminants remaining

in the system is directly dependent upon the geometry, fittings, etc, of

each particular piping system.

This report describes the laboratory system and test procedures

and presents data that characterizes the sampling efficiency of the side

stream tap for metal particles, small pieces of paper, and tape. Twenty

three tests were made with three flush flow velocities and two pipe sizes

selected as typical for the Bellefonte plant.

L.

4

FACILITY DESCRIPTION-

The test facility was constructed as shown in figure 1. The

facility had a closed loop with 6-in.-diameter PVC pipe connected through

interchangeable 10-in.- and 6-in.-diameter, 15-foot-long test sections.

Water for the test loop was supplied through a 1-1/2-in. pipe connected to

the municipal water system. The supply line was equipped with a pressure

regulator and a valve for flow control. A 1-1/4-in. valve was teed into

the supply line to provide a-contaminant addition port. Water in the

system was circulated by a centrifugal pump and metered by a calibrated

elbow meter located just downstream from the test section.

A flow control valve was installed between the pump and the test

section. Sidestream sampling taps of 2-in.-diameter clear acrylic plastic

with gate valve were installed 10 ft downstream from the entrance to each

test section. The 10-in.-diameter test section had a semicylindrical

observation window and the 6-in.-diameter test section had clear plastic

pipe at the tap site.

System volumes were approximately 160 gal with the

10-in.-diameter test section and 118 gal with the 6-in.-diameter section

installed. Maximum flow velocities were 7 ft sec-1 in the 10-in. section

-1 and 19-ft see in the 6-in. section. Sampling flow rate was adjusted to

approximately 15 gpm and the sample flow was replenished by the municipal

supply during sampling intervals.

_ owou 9 ~

-' 27

NANT 15 ALVE, I'/2 -OBSERVATION

STATIC WWINDOW, PRESSURE TAP, VALVE 1/4 6"I. D. ELBOW METER

PPLY

FLOW '6TYP

OBSERVATION WINDOW.

_10' TEST SECTION

S/2 SAMPLING VALVE, 2" GATE FLOW CONTROL VALVES, 6"BFV

4

TO SAMPLEI I FILTER

AL g" PVC

0

BOTTOM DRAIN VALVE

PUMP DRAIN VALVE ELEVATION, NTS

Figure I: Schematic Drawing of Beliefonte Proof Flush Sampling Test Facility

(_"" 1 60 r4o t- r4k"

. 6

EXPERIMENTAL

Contaminants

Contaminants were added to the test facility in measured batch

quantities. .The contaminants were:

1 . Metal filings which passed a 20 mesh and were collected on

a 40 mesh sieve.

2. Duct tape, 0.25-in. diameter.

3. Purge dam paper, 0.25-in. diameter. The paper added during

tests 14 and 15 was coated with Elmer's Glue-All and Elmer's

School Glue and dried at 400oF

Anaratus

A description of the test apparatus (pump, valves, manometers,

etc.) is given in appendix A.

Test Procedure

Upon completion of the test facility construction and prior to

contaminant addition, the system was filled, recirculated, and purged until

construction debris recovered from purging of the pump, bottom, and side

stream sampling valves was negligible.

With the pump activated, the flow velocity in the test section

was determined rby an elbow meter calibrated against a laser anemometer.

The laser anemometer was occasionally available for flow velocity

measurement during tests. Prior to each test, the system was filled and

~2

recirculated 30 to 60 min. The system was purged and the sidestream

sampling valve, pump valve, and bottom valve were checked for- contaminants

from previous tests. Measured quantities of contaminant materials were

added to the system and recirculated 5 min at known velocites. Sidestream

sampling with approximately 15 gpm sampling flow rate was performed at

intervals from 5 to 125 min by collection of contaminants on nylon filters

and 100 mesh wire screens. The pump was deactivated, the side port valve,

pump valve, and- bottom valve were purged, and the system was drained after

the final sampling interval of each test. Collected samples were dried and

weighed. The weight of contaminant collected at each sampling time was

recorded.

(

.8

RESULTS AND DISCUSSION

Test results are tabulated in appendix B and graphed in figures 2

through 10. Metal filings, totaling 175 g, were added to the system during

tests 1 through 3. Approximately 47 percent of the metal was not recovered

by flushing the system. Approximately 93 percent of the 450 g of metal

added for tests 5 through 8 was recovered. A significant portion (for

example, 21.9 g in test 7) of metal not sampled in the sidestream flow but

recovered during each test was flushed from the sidestream sampling gate

valve seat. The valve opening was less than 0.1 in. for these tests.

Relatively smaller amounts of metal (for example, 2.9 g in test 7) were

recovered from the 1-in. and 1.5-in. drain valves.

During tests with tape and paper contaminants, 0.01 to 0.1 g of

metal was recovered in most sidestream discharge samples. This metal was

apparently dislodged-from hideout sites and metal recovery from test 13 was

10 g lower than the average recovery for tests 5 through 8. Apparently

metal was required to replace that dislodged and sampled during tape tests

9 through 12. During test 4, 10 g of purge paper was added to the system.

Most of the paper dissolved, although a small amount of gelatinous material

was recovered in the sidestream sample. The duct tape added for tests 9

through 12 and the purge paper/glue added for tests 14 and 15 were less

dense than water. Approximately 95 percent of the tape and 88 percent of

the paper added-to the system was recovered. Most of the unrecovered

paper/glue probably dissolved. In an immersion test with 2 g of dried

(4000F) paper and glue in water for 20 min, 0.38 g (19 percent) dissolved.

F 9

Upon completion of test 15, a full flow strainer with 0.0029-in. openings

was placed in the system. After 2 h of recirculation and 10 pump cycles,

less than 0.25 g of contaminant (mostly metal) was collected in the

strainer. Tests 16 through 23 were run after the 10-in.-diameter test

section had been replaced by the 6-in.-diameter test section.

The tape sampling rate via sidestream sampling was nearly

identical at 10 and 19 ft see-1 in the 6-in. system and unchanged from the -1 rate at 7 ft see in the 10-in, system.

At both 10 and 19 ft sec-1 flow velocity, tape was trapped on the

downstream top side of the sampling tap, as well as on top of the

partially open gate valve. Occasionally, some of this was dislodged.

Tape trapped on the tap and valve seat was recovered at the end of each

test when the pump was turned off and the valve completely opened.

Recovery from the valve was -1 g more in tests 16 and 17 (10 ft se- 1

than in tests 9 through 12.

Although the calculated rate of removal was the same in all tape

tests, 10 percent less tape was recovered by sidestream discharge when

system velocity was 10 ft see-1 , and total recovery was 5 to 10 percent

less than at 7 ft see or 19 ft see-1

The metal sampling rate at 19 ft see-1 flow velocity was similar

to the rate at 7 ft see flow velocity in the 10-in.-diameter test

section. The metal test results at 10 ft sec- 1 are not in agreement with

any other test results. This is probably due to contaminant trapping down

stream from the control valve when the system is throttled to 10 ft see 1 .

o90

80

7 0

E50

0

40

20 LEGEND

o - METAL TEST S

10- a - METAL TEST 6 A - METAL TEST 7

X - METAL TEST 8 0 - I-assagag5

0 10 20 30 40 50 60 70 60 90 100 110 120 130

TIME CMIN)

Figure 2s BLNP Side Stream Sampling. Effect of Time on the Cumulati ve Amount of Metal Diacharged In the Side Stream. 10-Inch Tent SectIonj 7 ft/sec Water Velocity.

iota

so

so

70

so-

- 55 55I SII I

0 10 20 30 40 S6 60 70 80 9b01001 10120130~

Fligur- 3t BLNP Sidle S*~reom'Sompling. Effect of Time on, the Cumi~lotive Amounrt of Du.ic Top" DImchorged In, the SId" Sitrftm. 10-Inch Teat Sectionj 7 ft/eec Water Velocity.

1-6 F-h

0 w 0)

40-

10-

I I..

-. 4

*rw I"&"i -am -lam -. M .-" -""1 -00 .-4"" Ii ~ ~ Un U

o - TAPE TEST 9

u-TAPE TEST 10

A-TAPE TEST 11

X -TAPE TEST 12

r-11 (om rook rom om -m" -p" _FM -MO -pa -,a -"" -Am O" ... oo -wsp wasa

90

80

708 60

(050

X 40

30

20

LEGEND 10- -TES

O - PAPER/GLUE TEST 14 a - PAPER/GLUE TEST 15

0 10 20 30 40 50 60 70 60 90 100 110 120 130

TIME CMIn)

Figure 4s BLNP Side Stream Sampling. Effect of Time on the Cumulative Amount of Paper/Glue Discharged in ' the Side Stream. 10-Inch Teat Sectionj 7 f t/sec Water Velocity.

r- roo r"" "" , emo,"," -~ aa --m"a~ --w* o wo -- ai- Mm" "

1

i 10..8

0.4

H

J 0.2

(00.LEGEND

O - METAL CAVG, TESTS 5-8> a - TAPE CAVG, TESTS 9-12> A - PAPER/GLUE CAVGTESTS 14,I5.')

-f i

0 10 20 30I Isil

40 50 60 70 80 90 100 1 10 1 201

1 30

TIME Cmin>

Figure 5a BLNP Side Stream Sampling. Summary of Side Stream Dincharge of Contaminant verous Timej Cumulative Sample/Total Sampled in Dincharge. 10-Inch Teat Section) 7 ft/eec Water Velocity.

I

r- :r- r- - ra"_f0 - Pom-Rm -9aw _"W Woull- I -Jong^~ -on -ft" -O9 -mmoi --woi

100

70

left

30

20 LEGEND~

0 METAL TEST 20 - VELOCITY 10 flmea

-METAL TEST 21 - VELOCITY 10 rLmaa A -METAL TEST 22 - VELOCITY 10 F fk'/a

X -METAL TEST 23 - VELOCITY 10 fk/mfta 0

13 10 20 313 413 50 613 703 81 0 100 A 110 120 130

TIME CMI,,)

Figur-e 6: BLNP Side Str-eam Sampling. Effect of Time -on t~he Cumulative Amount of Metal Diacharged In the Side Stream. 6-Inch TGe Seationj 10 and 19 fIt/aec Watar Veloc~ty..

r- r rw - r -_ p -v-A -- rm" -j -. aw -. o -

90

70

0 id

A.

(0

40

30

LEGEND

o - TAPE TEST a - TAPE TEST

A - TAPE TEST

X - TAPE TEST

10 - VELOCITY 10 ft/em 17 - VELOCITY 10 fL/mfoa IS - VELOCITY 19 ft/mea

1Q - VELOCITY 10 ft/mea=

0 10 40 so 60 70 80 100 110 120 1SO

TIME cM In>

FIgure 7: BLNP Side Stream Sampling. Effook of Time on the Cumula tive Amount of Duak Tape Discharged In the Side Stream. 6-Inch TeEk Sotion; 10 and 19 ft/sec Waker Vloalty.

H I-fl

10

r"00 . r"O"" r"41

1-

0 11 10.8

J

00.6

0.4Il w

H

.

~0

0 -t

0

LEGEND

0 - METAL

a - METAL

A - TAPE X - TAPE

CAVG, TESTS CAVG,TESTS

CAVG,TESTS

CAVG,TESTS..... a I l

10 20 30 40 50 60 70 80 90 100 110 120

TIME Cmin*)

Figure 8, BLNP Side Stream Sampling. Summary of Side Stream Discharoe of Contaminant verous Time; Cumulative Sample/Total Sampled In Dincharge. 6-Inch Tet Sctlon Velocity 10 ft/eec Test. 160,17,20,21; Velocity 19 ft/mee Teto 1.8,19,22,23.

20,21D 22,23D 186, 17)

8,10Di

130

t--*-' r-ft rag" , ra" mm" . pw" w - MWOM . -Mom* _Mw -0 -Mal I -- awme i

8

r~ r' r~r~ r'~ - F -

fD

L L

0.

U E

L

z 0

H 1

Iz Idi

z 0 Z

0 0 -.1

-1

-2

-3

-4 -

10 20 30 40 so 60 70 80 90 100 1 10 1 20

TIME CMIn>

Figure 9s BLNP Side Stream Sampl ifng. Time Dependence of Log Concen Lr-at ion of Tape or Paper/Glue In 6he Side Stream Discharbe.

LEGEND

o - TAPE CAVG,TESTS 0-12> u - TAPE CAVG,TESTS 6, 17> A - TAPE CAVG.,TESTS 18..19

X - PAPER/GLUE CAVG,TESTS 14,16> Ii g * 1

g g

0

-1 L 0 0.

E

L-3

0

-4

0

.ETLCAG-ET358

z 0

0 LEGEND' o

J0 - METAL CAVG. TESTS 6-6>

ol - METAL CAVGTESTS 20,21)

A - METAL CAVGTESTS 22,23>

-5 I I I I I 1- II III

0 10 20 30 40 50 60 70 80 90 1100 le120 130

TIME CMin>

Flgure 10s BLNP Side Stream Sampling. Time Dependence of Log Concentraioon of Metal in 6he Side Stream Discharge.

This part of the system was under reduced pressure and the pipe may have

been only partially filled with water.

Figure 5 summarizes the test results from the 10-in, test section

and gives a comparison of the time necessary for sampling 95 percent of

metal, tape, or paper sampled. Figure 8 presents a similar summary of test

results from the 6-in, test section.

In figures 9 and 10, the log 10 of sidestream contaminant

concentration versus time is plotted. Contaminant concentrationwas

calculated by dividing grams contaminant recovered during a sampling

interval by total gallons of side stream discharged during the interval.

This was plotted against the midpoint of the time interval. The plot is

linear for tape and shows the sampling rate is nearly independent of test

section diameter and flush velocity in the test system. The glue/paper

results are similar for the first hour; deviation from linearity at longer

times probably results from imprecisions in collecting and weighing <0.05

g of the material. The log 1 0 of sidestream concentration of metal also

shows a fairly linear dependence on time to about 40 min, with the

exception of tests 20 and 21 (6-in, test section, 10 ft sec-), in which

conditions necessary to reduce the flow to 10 ft sec-1 changed the flow

characteristics of part of the system.

I

.20

CONCLUSION

The test results show concentration of contaminant in side

stream samples proportional to concentration suspended in flows. With the

exception of tests 20 and 21, where metal trapping probably caused

anomalous sampling rates, the results for contaminant sampling rates

demonstrate correlation with the equation:

C =Che-kt t 0

where: C = Sampled contaminant concentration

C Initial system contaminant concentration 0

h = Fraction of contaminant circulating in system

k Sampling rate/system volume

t = Sampling time

Since contaminant sampling rate is an exponentially decreasing

function of sampling tiLe, system cleanliness would not be measured t'

proof flushing beyond the time at which contaminant sampled had been

reduced by approximately 95 percent. Figures 5 and 8 show the time

required to sample 95 percent of metal and duct tape in the test loop is

approximately 15 and 60 min respectively. During these times any given

metal particle in suspension would have passed the sampling tap 100 to 300

times and a tape particle would have passed 400 to 1100 times if the

-1 average flow velocity was 7 to 19 ft sec . In addition to predicting

-21

maximum effective sampling times, the equation predicts that small amounts

of contaminants would be sampled even if recirculating proof flushing was

continued indefinitely. A final bit of information, evident in the test

tables, confirms that the bulk of contaminants trapped in a system will

likely be found in valve seats and dead legs.

C fIr RECOMMENDATIONS

Based on the information presented in this report, it is

recommended the following procedure be adopted during proof flushing

to establish the time necessary to remove 95 percent (or whatever

percentage required) of the collectable debris from the system.

1. Establish a stable sidestream sample flow and perform one short (15

min) sidestream sampling. Collect, sort, and weigh the sampled

contaminants.

2. A short time later, perform a second sampling of similar duration.

Collect and weigh the contaminants.

-kt 3. Using the equation Ct = C he , calculate k for the particular pipe

system and contaminants in question:

k = L.In (t2 - t 1) C2

t t is the time interval between the start of the two sidestream 2 1

sampling tests. C and C2 are specific contaminant concentrations in

the sidestream sample. If the sidestrezm sampling rate is constant,

volume in C1 and C2 cancels and

/ 1'

/1 /

*22

I \

.23

k = ln -veisht t weih 2 1 ight 2

The time necessary for sampling 95 percent of the contaminant initially

in the flow (C = 0.05 C0h) can be calculated:

t 95% = n -41 =.0 -k -k

4. Perform a third sidestream contaminant sampling at the end of the time

interval computed in step 3. Verify that the contaminants have been

reduced to the required level. If the contaminants were reduced to the

required level, further sampling will not yield additional information.

If not, reevaluate the time interval computed in step 3 using t - t1. I3 5. After completion of flushing, clean out all contaminant traps in bottom

deadend tees, pump, and valve housings.

.24

Apparatus

Pump: Fairbanks-Morse centrifugal, 12-in., figure 5721, 1 stage, 3000 gpm

at 15-ft head, 875 rpm, 12.125-in. impeller diameter, S/N K3C6076874

Pump Motor: U.S. Electric, unclosed, 15 hp, 3-phase, 60 hertz, 880 rpm,

S/N R-1714-02-277

Water Pressure Regulator: Mueller Company, Decatur, Illinois, 1-in.,

number 2, catalog number H-9300, maximum inlet

pressure 250 psi, outlet pressure range 25 to

84 psi (set below lower range limit to 15 psi).

Water Supply Valve: American Valve Gate Valve, bronze, figure 3R, 1-1/2

in., 125-lb class.

Contaminant Entry Valve: Jenkins Gate Valve, bronze, 1-1/4-in., 125-lb

class

Sampling Valve: NIBCO bronze gate valve, Union Bonnet, nonrising stem,

alloy solid wedge, 2-in. NPT, 300-lb class, P/N T-176-A

Drain Valves:

1. Test system; power bronze gate valve, 1-1/2-in. NPT, 125-lb

class

2. Pump; Consolidated Valve Industries, Inc., Apollo Ball Valve,

1-in.

Flow Control Val-ves (2): Keystone Valve Co, butterfly valves, 6-in.

Static Pressure Tap Valve: Circle Seal Valve, 1/4-in. NPT

Air/Water Manometer: 60-in, tube, Meriam Instrument Company

.25

Mercury Manometer: 50-in. U tube, scale, RC4317-1, Meriam Instrument

Company, model 10AA25WM

Anemometer: Spectra Physics He/Ne Laser Model 124B, TVA 472212

Stopwatches: Heuer, TVA 493079; Meylan, TVA 300613

Analytical balance: Ainsworth, TVA 361355

Platform scales: Howe 60809418

Sieves: U.S.A. Standard Testing Sieves, No. 20 (0.0331-in. opening), No.

40 (0.0165-in. opening), No. 100 (0.0059-in. opening).

Drying oven: Blue M Model OV-510A2, TVA 393714

L L

26

APPENDIX B

TABULATED TEST RESULTS

L

L

CONTAMINANT = 2 METAL FILINGS

Recovery from Sidestream Discharge

Sampling Time Interval

min

10

10.

10

Metal Recovered

8

2.59

0.80

0.89

Cumulative $ Recovered

10.4

Discharge Rate

gal/min

14.6

13.6

17.1

Metal flushed from bottom and pump valve Sidestream, pump valve flush Total 100 mesh metal Metal from system purge before next test Recovered metal Unrecovered metal

Percent recovered

C

.a

'27

1.0 g 5.13 g 1.08 g 0.88 g

12.37 g 12.36 g

49

.28

CONTAMINANT = 50 R METAL FILINGS



min

5

15

15

15

15

30

30

Metal Recovered

9

13.55

6.92

0.53

0.13

0.03

0.05

0.07

Cumulative I-Recovered

27.1

Discharge Rate

gal/min

14.9

40.9

42.0

42.3

42.3

42.4

42.6

Metal flushed from sidestream valve Metal flushed from bottom and pump valve Metal from system purge before next test Total 100 mesh metal recovered Recovered metal Unrecovered metal

Percent recovered

N/A 2.50 0.34 0.51

24.63 25.37

g g g g g

49

CONTAMINANT = 100 9 METAL FILINGS



min

5

15

15

15

15

30

30

Metal Recovered

9

20.57

11.24

1.16

0.28

0.15

0.18

0.10


20.6

Discharge Rate

gal/min

9

31.8

33.0

33.2

33.4

33.6

33.7

Metal flushed from sidestream valve Metal flushed from bottom and pump valve Metal from system purge before next test Total 100 mesh metal recovered Recovered metal Unrecovered metal

Percent recovered

C

-29

16.02 g 5.16 g N/A N/A

54.9 g 45.1 9

55

.30

TEST 4

CONTAMINANT = FO m METAL + 10 a PAPER

Recovery from Sidestream Tischarre


min

5

15

15'

15

Metal Recovered

g

9.97

6.98

7.50

2.68

Cumulative ' Recovered

19.9

Discharge Rate

gal/min

15

33.9

40.8

45.2.

Metal and paper flushed from sidestream valve Metal and paper flushed from bottom and pump valve Metal and paper flushed from pump valve Metal flushed from system before next test Recovered metal and paper Unrecovered metal and paper

Percent recovered

'10 g paper added before this time interval.

24.58 0.42 2.90

N/A 55.0

5.0

g g g

9 g

92

CONTAMINANT = 100 g METAL FILINGS



min

5 15 15 15 15 30 30

Metal Recovered

8

47.82 3.12 0.83 0.18 1 .78' 0.1 0.9'


47.8 50.9 51.7 51.9 53.7 53.8 54.7

Discharge Rate gal/min_

10.4 9.0 8.9 8.9

10.1 9.8 9.4

Average Concentration in Discharge

g/gal

9.20x10-1 2.3x10 2

6.2xi0 3

1.3x10-3 1.2x10-2

3x10 3x10 3

Metal flushed from sidestream valve Metal flushed from bottom valve Metal flushed from pump valve Metal from system purge before next test Total 100 mesh metal recovered Recovered metal Unrecovered metal

21.07 g 0.1 g 0.43 g 6.6 g 0.6 g

83.4 g 16.6 g

Percent recovered

*Hose from side stream discharge clamped off, reopened.

I(

.-31

C

83

C

.32

CONTAMINANT = 100 a METAL FILINGS


min

5 15 15 15 15 30 30

Metal Recovered

9'

57.82 9.15 1.66 0.21

0.1 0.1 0.1

Cumulative I Recovered

57.8 67.0 68.6 68.8 68.9 69.1 69.2

Discharge Rate gal/min

13.0 13.4 15.0 13.7 15.8 15.0 14.8


g/gal

8.90x10 1

4.6x10-2

1X0-3 4x10 2x10 1

2x10 2_

Metal flushed from sidestream valve Metal from bottom valve Metal from pump valve Metal from system purge before next test Total 100 mesh metal recovered Recovered metal Unrecovered metal

Percent recovered

14.58 g 0.1 g

2.79 g 2.25 g 0.92 g 89.7 g 10.3 g

W= bc M ra Ra nvery f"MI" -Q4Aaaf"a ni a In V. aRecovery

90

CONTAMINANT = 100 s METAL FILINGS

Recovery from Sidestream Discharre


min

5 15 15 15 15 30 30

Metal Recovered

g

65.17 3.33 0.31 0.17 0.05 0.05 0.05


65.2 68.5 68.8 69.0 69.0 69.0 69.0


13.8 15.0 15.0 15.0 15.0 15.0 15.0


g/gal

9.44x10-1 1.5x10-2

1x10-3 8x104 2xO1 4 1x104 1X10 4

Metal flushed from sidestream valve Metal from bottom valve Metal from pump valve Metal from system purge before next test Total 100 mesh metal recovered Recovered metal Unrecovered metal

Percent recovered

C

-33

21.9 g 0.1 g 2,8 g 2.3 g 0.8 g

96.8 g 3.2 g

97

-34

CONTAMINANT 100 a METAL FILINGS


Sampling Time Interval min

5 15 15 15 15 30 30

Metal Recovered

g

62.58 5.65 0.41 0.13 0.10 0.17 0.07


62.6 68.2 68.6 68.8 68.9 69.0 69.1


12.1 15.7 15.4 15.4 15.4 15.4 15.4


g/gal

1 .032 2.4l_10

2x 106xio-4 4x10-4 4x10_ 2x10

Metal flushed from sidestream valve Metal flushed from bottom valve Metal flushed from pump valve Metal from system purge before next test Total 100 mesh metal recovered Recovered metal Unrecovered metal

Percent recovered

18.57 g N/A

2.54 g 0.23 g 1.64 g 92.1 g 7.9 8

92

-35

CONTAMINANT = 19 a DUCT TAPE

RenMv"ry


min

Tape Recovered

8


Discharge Rate

gal/min


g/gal

15 15 15 15 15 30 30

2.70 5.26 3.12 0.76 0.18 0.29 0.05

18 53.1 73.9 78.9 80.1 82.1 82.4

13 13 13

15.5 15.5 15.5 15.5

Tape flushed from sidestream valve Tape flushed from bottom valve Tape flushed from pump valve Tape from system purge before next test Recovered tape

Percent recovered

4.15x0-2 2.70x10-2 1.60x10 2

3.3x10-3 8x101 6x104 1x1-I

1.75 g 0.1 g

010g 0.1 g

14.3 g

95

f A -qieqg% * U -, - - - , -- -&- A. = & w 96Rk ALES

-36

TEST 10

CONTAMINANT = 19 R DUCT TAPE



min

5 15 15 15 15 30 30

Tape Recovered

8

3.31 4.64 2.06 1.87 0.63 0.36 0.16


22.1 53.0 66.7 79.2 83.4 85.8 86.9

Discharge Rate

gal/min

9.5 9.5 9.5

13.9 13.9 15.5 15.5


g/gal

6.07x1o 2

3.26x10-2 1.45x10 2

8. 9x10 3.0x10-3

8x10 1_ 3x10


Percent recovered

0.89 g 0.1 g 0.1 g 0.4 g

14.3 g

95

TEST 11

CONTAMINANT = 19 g DUCT TAPE



min

Tape Recovered

g


Discharge Rate

gal/min


g/gal

5 15 15 1515 30 30

2.73 4.58 3.16 1.17 0.39 0.23 0.05

18.2 48.7 69.8 77.6 80.2 82.2 82.5

15 15 15 15 15 15 15


3.64x10 2

2.04x10-2 1 .40x10-2 5.2x10-3 1.7x10

5x101x104

1.11 g 0.1 g

0.23 g 0.13. g 13.8 g

Percent recovered

(c.37

C

92

-38

CONTAMINANT = 1 g DUCT TAPE


min

5 15 15 15 15 30 30

. Tape Recovered

g

3.90 5.84 2.19 0.66 0.32 0.12 0.06


26.0 64.9 79.5 83.9 86.1 86.9 87.3

Discharge Rate

gal/min

14.4 14.4 14.4 14.4 14.4 14.4 14.4

Average Concentration In Discharge

g/gal

5.42x102.70x10 2

1.01x10 2

3.1x1O-3 1.5x10-3

3x10 1x10


Percent recovered

1.18 g 0.1 g 0.1 g

0.23 g 14.5 g

.L. & :d &2hi ML&2 Pecove- f Am "'4A'M *" nm T% 11Recover

g7

.39

TEST II

.CONTAMINANT =.100 R METAL FILINGS



min

Metal Recovered

.9

Cumulative 9 Recovered


Average Concentration In Discharge

g/gal

5 15 15 15 15 30 30

55.70 2.27 0.32 0.09 0.08 0.25 0.63

55.7 58.0 58.3 58.4 58.5 58.7 59.3

10 9.6 9.6 9.6

10.8 10.8 13.1

Metal flushed from sidestream valve Metal flushed from bottom valve Metal flushed from pump valve Metal from system purge before next test Total 100 mesh metal recovered Recovered metal

1.11 1.58x10 2

6.9x10-3 6x105x10^ 8x 10

1 .6x10-3

17.13 g N/A

2.81 g N/A

1.82 g 81.1 g

Percent recovered

(c

C

81

40

TEST 14

CONTAMINANT = , PAPER + "GLUE-ALL" - DRIED 4000 F 1/4-IN. DIAMETER

Recovered g

2.42

2.06

0.40

0.10

0.05

0.05

0.08-

$1 Recovered

38.4

71.1

77.5

79.1

79.8

80.6

81.9

Discharge Rate

gal/min

15

15

15

15

15

15

15

Flush of valve: 0.24 g (-tape 0.09 g) Drain system; flush pump, bottom valve

Percent recovered

12rnL min

5

15

15.

15

15

30

30

.15 g 0.05 g

83.3

41

CONTAMTNA1~IT ii ~ -.

- A 6 -660n .SaMvoL GLUE - DR1IED 'UU ? - 1/4-IN. DIAMETER

Recovered 9

2.31

1.50

0.23

0.19

0.06

0.05

0.05

Recovered

48.8

80.0

84.8

88.8

90.0

90.0

91.0

Discharge Rate

gal/min

15

15

15

15

15

15

15

F F I

I I IC I I I I II".

IC

Time min

5

15

15

15

15

30

30

Flush of pump valve 0.06 g Drain system; flush pump, bottom valve <0.05 g

Percent recovered 92

TEST 15

.42

TEST 16

CONTAMINANT = 14.7 a DUCT TAPE



min

5

15.

15

15

15

30

30

Tape Recovered

9

2.83

6.21

1.00

0.61

0.27

0.29

0.34


19.3

61.5

68.3

72.4

74.3

76.3


11

15.6

15

15

15

15

78.6 15

Tape flushed from sidestream valve and top of tap to valve Tape flushed from bottom and pump valves Tape from system purge before next test Recovered tape

Percent recovered

Velocity through 6 in. pipe ='10 ft/sec

2.18 g 0.05 g

n/a 13.73 g

93.4

CONTAMTNAMT = 14.6 DUCT TAPE



min

5

15

15

15

15

30

30

Tape Recovered

g

1.91

4.65

2.50

0.85

0.23

0.21

0.03


13.1

44.9

62.1

67.9

69.5

70.9

71.1

Discharge _.Rate gal/min

13

14

15.5

15.5

15

15

15

Tape flushed from sidestream valve and top Tape flushed from bottom and pump valves Tape from system purge before next test Recovered tape

of tap to valve

Percent recovered

Velocity through 6 in. pipe = 10.5 ft/sec-1

(c

-43

C2.16 g

0.05 g 0.12 g 12.66 g

86.7

.44

CONTAMINANT = 14.9 DUCT TAPE



min

5

15

15

15

15

30

30

Tape Recovered

a

2.00

4.96

2.59

1.43

0.81

0.29

0.11

Cumulative ' Recovered

13.4

46.7

64.1

73.7

79.1

81.1

81.8

Discharge Rate

gal/min

11

15

15

16

16

16

17

Tape flushed from sidestream valve and top of tap to valve 1.28 g Tape flushed from bottom and pump valves 0.05 g Tape from system purge before next test 0.27 g Recovered tape

Percent recovered 98.

Velocity through 6 in. pipe at sidestream sample tap = 19.0 ft/sec

9

I I. Ii

I

-45

TEST 19

CONTAMINANT.= 14.0 g DUCT TAPE



min

5

15

15

15

15

30

30

Tape Recovered

8

2.34

6.36

2.03

1.14

0.A7

0.25

0.01


16.7

62.1

76.6

84.8

88.1

89.9

90.0


12.6

15

15

15

15

15

15

Tape flushed from sidestream valve and top of tap to valve 1.51 g Tape flushed from bottom and pump valves 0.05 g Tape from system purge before next test 0.47 g Recovered tape 14.6 g

Percent recovered 100

Velocity through 6 in. pipe at sidestream sampling tap = 19.4 ft/sec -1

C.

(.

C

-46

TEST 20

CONTAMINANT = 99.7 g METAL FILINGS



min

5

15

15

15

15

30

30

Metal Recovered

g

29.55

8.19

2.66

1.68

3.64

2.79


29.6

37.9

40.5

42.9

44.6

48.2

51.0

Discharge Rate

gal/min

11

15.7

15

15

15

15

Metal flushed from sidestream valve Metal from bottom and pump valves

Metal from system purge before next test Total 100 mesh metal recovered Recovered metal Uncovered metal

Percent recovered

Velocity through 6 in. pipe at sidestream sample tap = 10.1 ft/sec -1

20.37 g 4.91 g 2.20 g 2.14 g 80.5 &

80.7

47

TEST 21

CONTAMINANT = 100 a METAL FILINGS


Sampling Time Interval,

min

5

15

15

15

15

30

Metal Recovered

g

26.27

8.49

3.38

4.38

2.11

3.69

30


26.3

34.8

38.1

42.5

44.6

48.3

50.8

Discharge Rate

gal/min

10.1

14.9

14.3

16.1

16

16

16

Metal flushed from sidestream valve

Metal from bottom and pump valves Metal from system purge before next test Total 100 mesh metal recovered Recovered aetal Uncovered metal

Percent recovered

Velocity through 6 in. pipe at sidestream sample tap = 10.4 ft/sec -1

21.6 g 4.61 g 2.05 g 2.83 g

81.9 9

82

I L L

[ IC L

.48

CONTAMTNANT = 100 a METAL FILINGS



min

5

15

15

15

15

30

30

Metal Recovered

g

42.56

9.58

1.78

.0.43

0.40

0.32

0.20


4Z.6

52.1

53.9

54.4

54.8

55.1

'55.3


10.1

13.4

15.5

15.0

15.3

15.2

15.2

Metal flushed from sidestream valve Metal from bottom and pump valves Metal from system purge before next test Total 100 mesh metal recovered Recovered metal Uncovered metal

Percent recovered

Velocity through 6 in. pipe at sidestream sample tap = 19 ft/sec -1

17.00 g 4.37 g 0.90 g 1.46 g 79.0 g 21.0 g

79

49.

TEST 23

CONTAMINANT = 99.6 a METAL FILINGS



min

5

15

15

15

15

30

30

Metal Recovered

8

16.48

32.05

0.57

0.33

1.03

0.27


16.5

48.7

58.2

58.8

59.1

60.2

60.5


8.03

14.6

16.2

15.3

15.3

15.3

15.3

Metal flushed from sidestream valve and metal flushed from bottom and pump valves

Metal from system purge before next test Total 100 mesh metal recovered Recovered metal Uncovered metal

Percent recovered

Velocity through 6 in. pipe at sidestream sample tap = 19 ft/sec -1

(c

17.72 g N/A

1.35 g 79.3 g 20.3 g

80

I - , *

ENCLOSURE 2

INFORMATION PACKAGE FOR

REQUEST OF APPROVAL FOR

REDUCTION IN TVA'S COMMITMENT

TO REGULATORY GUIDE 1.37 (ANSI N45.2.1-1973)

TVA-TR75-1 Rev. 6

REGULATORY GUIDANCE NUMBER, TITLE. AND DATE

TABLE 17.1A-4A (Sheet 1)

QUALITY ASSURANCE STANDARDS FOR DESIGN AND CONSTRUCTION (REGULATORY GUIDANCE)

APPLICABLE TO THE BELLEFONTE. HARTSVILLE, AND YELLOW CREEK NUCLEAR PLANTS j6

- ... CONFORMA~r STATUS

Regulatory Guide 1.28 Quality Assurance Program Requirements (Design and Construction), Rev. 0, June 7, 1972

Regulatory Guide 1.37 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants, Rev. 0, March 16. 1973

Regulatory Guide 1.38 Quality Assurance Requirements for Packaging, Shipping,

Receiving, Storage. and Handling of Items for WaterCooled Nuclear Power Plants, Rev. 2, May 1977

Regulatory Guide 1.39 Housekeeping Requirements for Water-Cooled Nuclear Power Plants Rev. 2, September 1977

Regulatory Guide 1.30 Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electric Equipment, Rev. 0. August 11, 1972

QUALITY ASSURANCE STIANDA NUMBE AN TITLE

ANSI N45.2-1971 Quality Assurance Program Requirements for Nuclear Power Plants

ANSI N45.2.1-1973 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants

ANSI N45.2.2-1972

Packaging, Shipping, Receiving Storage and Handling of Items for Nuclear Power Plants

ANSI N45.2.3-1973 Housekeeping During the Construction Phase of Nuclear Power Plants

ANSI N45.2.4-1972 Installation, Inspection, and

Testing Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations (IEEE-336-1971)

ANDIOR REMARKS

Conforms fully.

Conforms fully.

Conforms fully except as noted: In accordance with ASME QA Case

78N45.2.2-01-0, welding electrodes hermetically sealed

in metal containers may be .stored under conditions described

for level C items unless other storage requirements are specified by the manufacturer.

Conforms fully.

Conforms fully. Note: ANSI N45.2.4 states that the Appendixes are not a part of the standard. Therefore OEDC does not consider the Appendixes to ANSI N45.2.4 to be mandatory.

0

Ft

(D

Ft

W 'TVA-TR75-W Rev. 7

TABLE 17D-1

QUALITY ASSURANCE STANDARDS FOR DESIGN AND CONSTRUCTION

(REGULATORY GUIDANCE)

APPLICABLE TO THE BELLEFONTE, HARTSVILLE, AND YELLOW CREEK NUCLEAR PLANTS

(Sheet 1)

REGULATORY GUIDANCE NUMBER, TITLE, AND DATE

Regulatory Guide 1.28 Quality Assurance Program Requirements (Design and Construction), Rev. 0, June 7, 1972

Regulatory Guide 1.37 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants, Rev. 0, March 16, 1973

Regulatory Guide 1.38 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for WaterCooled Nuclear Power Plants, Rev. 2, May 1977

Regulatory Guide 1.39 Housekeeping Requirements for Water-Cooled Nuclear Power Plants Rev. 2, September 1977

QUALITY ASSURANCE STANDARD NUMBER AND TITLE

ANSI N45.2-1971 Quality Assurance Program Requirements for Nuclear Power Plants

ANSI N45.2.1-1973 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants

ANSI N45.2.2-1972 Packaging, Shipping, Receiving Storage and Handling of Items for Nuclear Power Plants

ANSI N45.2.3-1973 Housekeeping During the Construction Phase of Nuclear Power Plants

CONFORMANCE STATUS AND/OR REMARKS

Conforms fully.

Conforms fully except as noted:

Acceptance criteria for Class B

(Section 3.1.2, item 5) is no particles larger than 1/8 inch in

any dimension. This exception only

applies to BLN purge dam materials.

Conforms fully except as noted: In accordance with ASME QA Case 78-N45.2.2-01-0, welding electrodes hermetically sealed in metal containers may be stored under conditions described for level C items unless other storage requirements are

specified by the manufacturer.

Conforms fully.

0 0

0

0 WI PA

WI

ANSI N45.2.1 VARIANCE REQUEST

1. PROPOSED CHANGE

According to Topical Report, TVA-TR75-1, Rev. 6, Table 17.1A-4A, TVA conforms fully to ANSI standard N45.2.1 - 1973. TVA requests approval of exceptions to the ANSI standard with respect to purge dam material (glue and paper). We propose that the acceptance criteria for purge .dam particulates be established as "up to 1/8-inch in any dimension" when the system cleanness is evaluated by examining a 20 mesh strainer, or equivalent, as described in section 3.1.2 of the reference ANSI standard. We also propose that it be acceptable to allow the adherent purge dam material still present after flushing to the 1/8-inch criterion to remain on the pipe wall.

2. REASON FOR CHANGE

Purge dams are used to form barriers inside the pipe so that the atmosphere inside the pipe can be purged with argon before the stainless steel pipe is welded. The early purge dams were made with Elmer's Glue-All, which is relatively insoluble, and Dissolvo paper. The more soluble Elmer's School Glue and Dissolvo paper are now being used. When the purge dam is placed too close to the weld, the solubility of both glues is significantly reduced by reaction to the heat of the weld.

Purge dams have been used extensively throughout the stainless steel systems. The flushing of these systems to the surface cleanness criteria and the strainer evaluation particulate criteria of ANSI N45.2.1 - 1973 has not been practical as demonstrated by one years flushing experience on Bellefonte unit 1. Flushing has been done with* demineralized water and also with 5-percent acetic acid. In both cases some adherent purge dam residue (both glue and glue impregnated paper) remains on the pipe interior at the purge dam location. Also, purge dam particulates up to approximately 1/8 inch continue to be occasionally caught on the flush strainer (or equivalent) after months of flushing on a single flow path, indicating that 1/8 inch is an end point for flushing this material. Continuing to flush past this point does not materially improve removal of purge dam residues.

3. BASIS FOR CONCLUSIONS

TVA believes that the reduced commitments in the proposed revised .program continue to satisfy the criteria of Appendix B and the QA program description commitments previously accepted by the NRC for the following reasons:

a. The abrading purge dam particles demonstrated varying degrees of plasticity--from soft and pliable (when not heat affected) to brittle enough to break in a person's fingers (when heat affected). Refer to Attachment B.

E83146.01

@I2

A safety analysis has been done showing that occasional 1/8-inch purge dam particles will not jeopardize plant safety. Refer to Attachment A.

b. The residual purge dam on the pipe wall will slowly dissolve. Refer to Attachment B.

c. The glue will not have any detrimental metallurgical effects on the pipe wall. Refer to Attachment C.

The above results are summarized in the final report to NCR 1725.

Refer to Attachment D.

E83146.01

ATTACHMENT A

NUCLEAR SAFETY ANALYSIS

. -. .. .~wm- - V-

EN DES CALCULATIONSREVIEW OF PURGE DAM PARTICULATE IN PRIMARY SYSTEMS

SYSTEM(S) N/A sAR1 CION(S)

PREPARING ORGANIZATION REV (FOR MEDS USE) MEDS ACCESSION NUMBER

NEB-NSA SAl APPLICABLE DESIGN BRANCHIPROJECT

DOCUMENTS IDENTIFIERS

R1

R2

KEY NOUN4S Insoluble Glue, R3

Purge Dam, FlushingRO RI R2 R3

DATE FJEARED G

T. C. Price

CHECKED

ATTACHMENTS MICROFILMED:

LIST ALL PAGES ADDED BY THIS REV:

LIST ALL PAGES DELETED BY THIS RZV:

STATEMENT OF PROBLEM

Overheating of glue used for attachment of paper purge dams made removal by flushing difficult. Request to evaluate safety systems to determine effects of particulate an ability of system to perform safety function.

LIST ALL PAGES* CHANGED BYTHIS REV:

ABSTRACT

As requested by MEB memo dated July 12, 1982 (MEB safety analysis review on the effects of glue and seven safety-related systems.

820715 008), NSA performed the paper purge dam particulates in

The conclusions of the evaluation are as follows:

a. With exceptions as noted, the 1/8-inch acceptance criteria for purge dam particulate will be acceptable from a safety standpoint.

*b. Based on assumptions, NEB recommends that whatever flushing technique required be used to clean the piping. It is recommended that those portions of systems where areas of concern have been noted be flushed by that technique that provides the greatest confidence the piping system will meet the assumptions.

*c. B&W and/or TVA must justify the acceptability of 1/8-inch particulate in the reactor coolant system.

*d. Process pump seals and reactor coolant pump seals should be evaluated in more detail to determine the effect of particulate.

*See attachment 2 for resolution.

*Use revision log (form TVA 10534) if more room is required

TITLE

REV

TVA 10697 (ENDES-7-78)

ATTACHMENT 1

Page 1 of 3

NSA REVIEW OF PURGE DAM PARTICULATE IN PRIMARY SYSTEMS

A. Background

Paper purge dams utilized during welding of stainless steel were located too close to the weld area, resulting in overheating of the glue used for attachment of the paper purge dams. This overheating has made removal (by system flushing) of the purge dam material difficult. NSA was requested to evaluate the seven systems listed to determine the effects of glue and paper purge dam particulate on the ability of the system perform its intended safety function.

The systems evaluated were:

a. Makeup and purification (MP) system b. Decay heat removal (DUR) system c. Waste disposal (WD) system d. Reactor building spray (RBS) system e. Spent fuel cooling (SFC) system f. Chemical addition and boron recovery (CABR) system g. Core flood (CF) system

B. Assumptions

The following assumptions were made to facilitate completeness of the review.

a. Glue and paper purge dam particulate vill be limited to 1/8-inch or less.

b. The number of particles (quantity of particulate) in any given system or portion of a system at any given time will be small. The assumption was made as size alone did not appear to be the only criteria, especially since we were concerned about plugging of lines, etc.

c. Particulate in the reactor coolant (RC) system will be reviewed by others to determine impact, i.e., if the system dumps into the RC system, this is acceptable from the system standpoint.

d. Particulate was assumed to be soft and malleable.

e. Only systems or portions of systems which perform primary safety functions were analysed in detail. However, interfaces with systems that perform primary safety functions were reviewed.

- - -- ~ .~. ,-.~'..

V.

Page 2 of 3


C. Results of Evaluation

1. The following generally summarizes the results of the

evaluation.

a. No adverse safety effects on process piping.

Justifications system piping is not small enough to be

obstructed by 1/8-inch particulate.

b. No adverse safety effects on system valves.

Justification: purge dam particles are too small and not

rigid enough to prevent valve opening or seating.

c. No adverse safety effects on drain or vent lines.

Justification: drain and vent lines serve no primary

safety function.

d. No adverse safety effects on instrument lines.

Justification: instrument lines are 1/4-inch, and pass

no flow that would cause entrainment of particulate.

e. No adverse safety effects on flow orifices or pressure

limiters. Justification: flow orifices and pressure

limiters are not small enough to be obstructed by 1/8-inch

particulate.

f. No adverse safety effect on heat exchangers.

Justifications tubes in heat exchangers are too large to

be obstructed by 1/8-inch particulate.

2. Specific results by system are summarized below:

a. The MP system performs primary safety functions of high

pressure injection (UPI) postaccident, and reactor coolant

pump seal cooling and boration control during normal

operation. The majority of this system is covered by

general anmeary above. However, specific areas of concern

include the lines to the reactor coolant pump seals, and

the fact that the 1/8-inch particulate does not meet the

minimum water chemistry standards per B&W equipment

specification and water chemistry requirements of 0.1 ppm

suspended solids.

b. The DUR system performs primary safety function of low

pressure injection (LPI) postaccident, and decay heat

removal postaccident and normal shutdown. No specific

areas of concern were uncovered for the DHR system.

However, it should be noted that the DIE system interfaces

directly with the RCS which was not covered in this

evaluation (see assumption c).

,4o , !.6;VvA*

Page 3 of 3


c. The WD system performs no primary safety function that can

be impeded by particulate. Its interfaces with other

systems is such that it would not be excepted to be of

concern for normal operation.

d. The RBS system performs the primary safety function of

containment energy removal postaccident. The evaluation

concluded no adverse effects in any areas.

e. The SFC system performs the primary safety function of

spent fuel cooling. The evaluation included effects of

of particulate on fuel cooling and flow blockage in the

pool. The evaluation concluded no adverse effects in any

area.

f. The CABR system performs no primary safety function that

can be impeded by the particulate. Its interface with

other systems that perform primary safety functions was

evaluated and determined not' to be a concern.

g. The CF system performs the primary safety function of

emergency core cooling during a LOCA. However, the

presence of particulate material will not prevent the

system from performing its intended safety function.

Conclusion of Evaluation

The following conclusions are based on numerous conversations with MEB

personnel and reflect NEB's understanding of what may be required to

obtain a reasonable margin of confidence that piping systems nave been

adequately flushed.

a. With exceptions as noted, the 1/8-inch acceptance criteria for

purge dam particulate will be acceptable from a safety standpoint.

b. Base on assumptions in part B. above (in particular a. and b.),

NEB recoMands that whatever flushing technique required be used

to clean the piping. It is recommended that those portions of

systems where areas of concern have been noted be flushed by that

technique that provides the greatest confidence the piping system

will meet the assumptions.

c. B&W and/or TVA must justify the acceptability of 1/8-inch

particulate in the reactor coolant system.

d. Process pump seals and reactor coolant pump seals should be

evaluated in more detail to determine the effect of particulate.

E52238.02

Attachment 2

The following are resolutions of items b, c, and d of the Conclusions of Evaluation section of the report. These resolutions were made after completion of the evaluation in 1982.

b. MEB has verified they will use that method which shows the greatest confidence the piping system will be clean and meet the assumptions in the NEB report.

c. Based on results of stirred autoclave tests performed by the Division of Nuclear Power temperatures of 40007 or above would dissolve the glue in less than 100 hours. Thus, any glue particulates entering the reactor vessel during power operation (6300F) would not affect core cooling.

d. Cyclone separators have been placed in the seal cooling lines of process pumps. The separators are specifically designed to remove particulate; however should 1/8 or less size particles enter the seals, in our judgement, the particulate should not adversely affect the seals due to the small quantity and the material composition.

E53136.02

ATTACHMENT B

SOLUBILITY TESTS

e

TECHNICAL REPORT

E13 820927 005 REPORT NO.:

M81-82-4184SHEET NO.:

DIVISION OF POWER SYSTEM OPERATIONS 1 of 3 sheets

LOCATION: Central Laboratories - PSC - Chattanooga DATE OF WORK:

SUBJECT: BELLEFONTE NUCLEAR PLANT - TESTING THE SOLUBILITY DAn oa RORT: 924182 OF GLUE USED IN PURGE DAMS

COPIESSENTTO: Darrell Drouhard, ARMS, Lab Files, Willene Robertson F4A IIB:Rbca~ne APOEDB:HlayA. f

PREPARED BY: Delsa IipdaeyfRJS CHECKED BY: APPROVED BY:

Objective: To test the solubility of Elmer's Glue All versus the solubility of Elmer's School Glue (both products of the Borden Company) used in purge dams under specified laboratory conditions which approximate the conditions in a nuclear reactor and the interfacing piping system.

Introduction

On August 2, 1982, the Metallurgical Laboratory Section was requested to perform stirred autoclave tests at 200.F, 300"F, 400*F, and 500.F to determine the solubility of glue used in purge dams under conditions approximating those in a nuclear reactor and the interfacing piping systems. The two types of glue were placed on thirty-two stainless steel test coupons which underwent various baking, soaking, and drying procedures before being placed in the autoclave and tested at the specified temperatures. (See Table I.) The coupons were periodically removed from the autoclave and

examined. Autoclave testing was continued until a solubility rate at each temperature could be determined. Percent weight loss was used to indicate the solubility rate.

Equipment

Various laboratory equipment was used to perform the tests under the conditions

specified. A laboratory furnace and drying oven were used for the baking and drying procedures. The five percent acetic acid solution was heated in a beaker on a hot plate. An autoclave with a stirring head was used to approximate

the conditions in a nuclear reactor and the interfacing piping system. All weights were determined by using a Gram-atic four place balance.

Test Procedure

The coupons were ground on 240 grit paper to give a smooth surface and then

cleaned ultrasonically in acetone. A view of these coupons is shown in Figure 1A. Each sample was weighed and the results recorded. (See Table II.) Elmer's Glue All was applied to sixteen coupons and Elmer's School Glue to

the remaining sixteen. The glue was allowed to cure for twenty-four hours at room temperature. A sample of each glue type after curing is shown in Figure 1B. The weights of the coupons were determined after curing and recorded. (See Table II.) Eight coupons each of both the Glue All and the School Glue were baked in a 400OF furnace for approximately two hours. A sample of each glue type after baking is shown in Figure 1C. The remaining eight coupons of each glue type were baked at 500*F for approximately two

TVA 6474A (PO-2-73)

M81-82-4184 Sheet 2 of 3 September 24, 1982

hours. The 500.F baking temperature was used instead of 600*F - 700.F

temperature originally requested because the glue charred and flaked

off after baking at 650.F. (See Figure lD.) After the coupons cooled,

their weights were determined and recorded. (See Table II.) Four Glue All

test coupons baked at 400*F and four baked at 500*F were soaked for

twenty-four hours in five percent acetic acid solution heated to 145F.

The same soaking procedure was used for the Sch6ol Glue test coupons baked

at both temperatures. After soaking in acetic acid,. the coupons were

rinsed in running warm water and dried in a.laboratory oven. After drying,

they were weighed and the results recorded. (See Table II.)

At this point the test coupons were ready for autoclave testing at 200-F,

300-F, 400-F, and 500.F. The tests were performed using 6500 ppm boric

acid buffered with lithium hydroxide to a pH between 5 and 6. After the

solution was prepared and placed in the autoclave, coupons to be tested

at a specific temperature were placed on the bottom of the autoclave bomb.

The autoclave was heated to temperature and the stirring head was used

to agitate the solution. The coupons were removed periodically, dried,

and weighed. The pH of the solution was also checked periodically and

adjusted or changed to maintain a pH between 5 and 6. Autoclave testing

was continued until a solubility rate at each temperature could be

determined.

Explanation of Results

Some experimental procedure and equipment problems were encountered.

As was pointed out earlier, baking at 650.F caused the glue to char and

chip off from the coupons. This baking temperature was lowered to 5000F.

The glue curled up on coupon No. 11 during the acetic acid soak.

(See Figure 1E.) Care was taken during soaking not to allow the glue

surfaces to touch. Test coupons tested at 300*F had approximately half

of their glue chipped off or curled up during testing (Figure 1F) possibly

due to contact with the stirrers. The coupons affected were No. 11 and

No. 7. Coupon No. 32 was also chipped upon completion of the second

autoclave run at 200*F. These abnormalities are reflected in the Percent

Weight Loss versus Time graphs. Glue curling and peeling off test coupons

was also observed after the second autoclave run at 400*F. (See Figure 2A.)

It was detected upon removal of the coupons from the autoclave. After

drying the glue was still soft. Deposits of glue were found in the

autoclave but could be easily removed. (See Figure 2B.) At 500*F testing

the glue flaked off in the autoclave and care had to be taken not to remove

the glue from the coupons when handling. (See Figure 2C.) Test coupons

No. 9 and No. 17 (Figure 2D) had all of the glue removed except several

spots. These-weights were lower than the original weights recorded for the

samples before glue was applied. The samples were cleaned and reweighed.

These weights were taken as the original weights of the coupons and used

in the weight loss percentage calculations.

Two sets of heaters in the autoclave had to be replaced and returned to the

manufacturer for evaluation. When the second set of heaters burned out,

a hole was also burned in the case so testing was continued at minimum

pressure at each temperature. The building line voltage was reduced to

ensure that the heater maximum voltage was not exceeded. .A power outage

M81-82-4184 Sheet 3 of 3 September 24, 1982

after hours caused an approximate test time to be set for the nonacetic acid soak test coupons at 400.F for the first autoclave run. This

approximation was based on a straight line curve of a slope of 1 from the results of the second autoclave run. The approximation was seven hours. Test coupons affected were No. 6, No. 14, No. 22, and No. 30.

The coupons baked at 400.F generally had a slightly faster rate of glue removal (approximately 2 - 4 percent) than those baked at 500*F. This

percentage did not include those test coupons whose glue curled or flaked off during testing. Those coupons were not representative of the group tested.

Soaking in acetic acid only increased the solubility from 1-3 percent in most cases. In Table II it is shown that the coupons experienced a

slight weight gain after soaking in the 5 percent acetic acid solution.

The glue weight after soaking was used as the total glue weight before

autoclave testing and was used in calculating weight loss. (See Note 1

on Table II.) The glue weight after baking was used as the total glue

weight for the coupons that did not undergo the soaking procedure. (See Note 2 on Table II.)

The pH was monitored during testing and a summary of the results are

given in Table III. As necessary to maintain a pH between 5-6, the solution was buffered with lithium hydroxide or a new solution was

prepared.

A summary of the data indicating autoclave testing temperature, time, and percent weight loss f or each coupon is given in Table IV. Percent weight loss versus testing time graphs are given in Figures 3-10.

Conclusions

Based on the results given, temperatures of 400*F and above would

adequately remove both glue types from the purge dams in less than 100 hours. The Elmer's Glue All was generally slightly more soluble

at temperatures of 300.F and above than the School Glue. Baking the test coupons at 400*F produced a more soluble product for both glue types than baking at 500*F. Soaking in acetic acid increased the solubility slightly on both glue types.

DLL:RJS:SAV Attachments

TABLE I DESCRIPTION OF TEST COUPONS

Coupon No. Glue Type Baking Temp., "F Acetic Acid Soak Autoclave Testing Temp.,

1 Glue All 400 Yes 500 2 Glue All 400 Yes 400 3 Glue All 400 Yes 300 4 Glue All 400 Yes 200 5 Glue All 400 No 500 6 Glue All 400 No 400 7 Glue All 400 No 300 8 Glue All 400 No 200 9 Glue All 500 Yes 500

10 Glue All 500 Yes 400 11 Glue All 500 Yes 300 12 Glue All 500 Yes 200 13 Glue All 500 No 500 14 Glue All 500 No 400 15 Glue All 500 No 300 16 Glue All 500 No 200 17 School Glue 400 Yes 500 18 School Glue 400 Yes 400 19 School Glue 400 Yes 300 20 School Glue 400 Yes 200 21 School Glue 400 No 500 22 School Glue 400 No 400 23 School Glue 400 No 300 24 School Glue 400 No 200 25 School Glue 500 Yes 500 26 School Glue 500 Yes 400 27 School Glue 500 Yes 300 28 School Glue 500 Yes 200 29 School Glue 500 No 500 30 School Glue 500 No 400 31 School Glue 500 No 300 32 School Glue 500 No 200

TABLE II COUPON WEIGHT INFORMATION

After Glue After After

Original, Curing, Weight, Baking, Acetic Acid Final, Weight Loss,

Coupon No. grams grams grams grams Soak, grams grams %

1 74.7241 74.9109 0.1868 74.8977 74.8895 74.7343 94.0

2 73.2292 73.4927 0.2635 73.4720 73.4736 73.2538 90.0

3 73.7741 73.9874 0.2464 73.9719 73.9738 73.9400 17.0

4 75.2413 74.4562 0.2149 75.4395 75.4358 75.4183 9.0

5 77.0026 77.2199 0.2173 77.2001 - 77.0073 98.0

6 75.1395 75.3126 0.1731 75.2996 - 75.1568 89.0

7 75.0144 74.1793 0.1649 74.1667 - -74.0368 85.0*

8 73.0487 73.2597 0.2110 73.2424 - 73.2251 9.0

9 74.7561 75.0074 0.2513 74.9794 74.9817 74.7603 98.0

10 75.8736 76.0855 0.2119 76.0620 76.0650 75.8956 88.5

11 72.6493 72.9544 0.3051 72.9260 72.9280 72.7715 56.0*

12 71.8378 72.1922 0.3544 72.1539 72.1638 72.1441 6.0

13 74.8839 75.1272 0.2433 75.0995 - 74.9021 92.0

14 74.5564 74.8564 0.3200 74.8252 - 74.5959 79.0

15 77.2217 77.4838 0.2621 77.4555 - 77.3936 26.5

16 75.4722 75.7613 0.2891 75..7322 - 75.7254 3.0

17 73.3290 73.4191 0.0901 73.4069 73.4079 73.3310 97.5

18 73.1474 73.3413 0.1939 73.3140 73.3260 73.1779 83.0

19 74.1186 74.2996 0.1810 74.2744 74.2830 74.2459 23.0

20 81.0809 81.3243 0.2433 81.2910 81.3047 81.2835 10.0

l 73.2422 73.4107 0.1685 73.3853 - 73.2475 96.0

22 74.7590 74.9092 0.1502 74.8887 - 74.7783 85.0

23 81.0906 81.2685 0.1779 81.2421 - 81.2162 17.0

24 79.5230 79.6673 0.1443 79.6478 - 79.6426 4.0

25 81.6176 81.8737 0.2561 81.8359 81.8446 81.6303 94.0

26 80.5823 80.7285 0.1462 80.7010 80.7055 80.6006 85.0

27 81.3655 81.5577 0.1922 81.5227 81.5297 81.5039 16.0

28 73.5074 73.6571 0.1497 73.6316 73.6367 73.6271 11.0

29 73.3776 73.5433 0.1657 73.5129 - 73.3927 89.0

30 78.7506 78.9143 0.1637 78.8825 - 78.7735 84.0

31 80.0651 80.2448 0.1797 80.2125 - 80.1926 13.5

32 75.8393 76.0255 0.1862 75.9971 - 75.9846 8.0

*Glue chipped off during testing.

To calculate weight loss percentage:

Note 1 - Acetic acid soaked coupons

(Goupon t. Original) (C Final Original Weight Loss, % =After Soak - Weight - coupon wt. - Weight / 100% Noeght Loscei adCoupon wt. Original

Wter Soak -Weight/

Note 2 - Nonacetic acid soaked coupons

Weight Loss, % = X 100%

TABLE III pH CHANGES DURING TESTING

Temperatures 1st Run 2nd Run Tested, oF Before/After Before/After

500* 5.5/5.1 5.7/5.9

500 5.5/5.1 5.7/5.9

400* 5.9/6.1** 5.3/4.3

400 5.6/5.5 5.9/6.1**

300* 5.2/4.6

300 5.2/5.5 5.2/4.6

200* 5.5/5.9 5.5/6.2**

200 5.5/5.9 5.5/6.2**

*Acetic Acid Soaked Coupons **Solution Changed After Run

3rd Run Before/After

5.4/4.9

5.4/4.9

5.3/4.3

TABLE IV DATA SUMMARY

Glue All - Baking Temperature 400.F - Acetic Acid Soak

Autoclave Testing Temp., 6*? .Coupon No.

Total Time,. Hours

Weight Loss,

Glue curled.

School Glue - Baking Temperature 400F - Acetic Acid Soak

500 40 97.5 400 44 83.0 300 64 23.0 200 90 10.0

Glue All - Baking Temperature 400*F - No Acetic Acid Soak

500 40 98.0 400 51 89.0

300 78 85.0 200 90 9.0

School Glue - Baking Temperature 400*F - No Acetic Acid Soak

500 40 96.0 400 51 85.0 300 78 17.0 200 90 4.0

Glue All - Baking Temperature 500*F - Acetic Acid Soak

500 40 98.0 400 44 88.5 300 64 56.0 200 90 6.0

School Glue - Baking Temperature 500.F - Acetic Acid Soak

500 400 300 200

40 44. 64 90

94.0 85.0 16.0

'11.0

Wt. lower than orig. Glue curled.

Glue curled. Half glue flaked off.

Glue curled.

Glue curled. Half glue flaked off

Glue curled.

1 2 3 4

500 400 300 200.

40 44 64 90

Comments

94.0 90.0 17.0

9.0

17 18 19 20

5 6 7 8

21 22 23 24

9 10 11 12

25 26 27 28

I

TABLE IV DATA SUMMARY (CONTINUED)

Glue All - Baking Temperature 500*F - No Acetic Acid Soak

Autoclave Testing Temp.,Coupon No.

Total Time, Hours

Weight Loss,

Glue cracked, stayed on.

School Glue - Baking.Temperature 500aF - No Acetic Acid Soak

Glue curled.

Glue flaked in one area.

13 14 15 16

500 400 300 200

40 51 78 90

Comments

92.0 79.0

26.5 3.0

29 30 31 32

500 400 300 200

40 51 78 90

89.0 84.0 13.5

8.0

B. Appearance of School Glue (left) and Glue-all (right) after curing.

A. As received photograph.

C. Glue-all (left) and School Glue (right) after curing and 400*F baking.

E. Test coupon acid soak.

No. 11 after acetic

of glue after 650*F

Figure 1 - Solubility of Glue in Purge Dam

F. Coupon No. 7 after 300*F trial in autoclave.

and Interfacing Piping System.

Chipping baking.

A. Glue after 400*7 testing in autoclave.

B. Deposits on the bottom of autoclave after 400*7 testing.

Flaking of glue after 500.7 testing.

Coupons Nos. 9 and 17 after 500*F testing.

Figure 2 - Solubility of Glue in Purge Dam and Interfacing Piping System.

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ATTACHMENT C

METALLURGICAL TESTS

Yv sos..sm .SME '83 0 1 2 6 00 1 UN1TED STATES GOVERNMENT8

Memorandum TENNESSEE VALLEY AUTHORITY

9i :C. E. Roberts, Supervisor, Codes, Standards, and Materials Section, W11C114 C-K

FROM : W. H. Childres, Supervisor, Singleton Materials Engineering Laboratory Section (Acting), SME-K

DATE January 26, 1983

SUBJECT: BELLEFONTE NUCLEAR PLANT - METALLOGRAPHIC EXAMINATION OF THE 304 SS PIPE WITH PAPER.ANP GLUE ON ITS ID SURFACE

. In response to request 5-7-82-2, the section of 304 SS pipe with purge dam paper and glue on its internal surface is shown in photograph 1. The thermocouple wires connected to the inner surface of the pipe are also shown. Figure 1 gives the dimensions of the specimen as received by SME.

. A longitudinal section through the paper/glue in the middle position of the specimen was taken for metallographic examination. The location of each section relative to the thermocouple wires can be identified. The longitudinal specimen was cut into four sections for mounting and polishing. The layer of paper and glue is identified in the micrographs. Photographs 2a through 2d show the id surface of pipe at various points along the charred paper and glue after etching with 10 percent oxalic acid. These pictures, taken at 100X magnification, show the austenite grain structure of the 304 SS to be free of intergranular attack. Other photographs, 3a through 3d, taken at 500X, further illustrate no intergranular attack due to paper and glue.

A sample of the glue and paper was analyzed for leachable halogens and results are given in the attached chemical analysis test report.

W. H. Childres

TKC:ASH cc: MEDS, W5B63 C-K

Principally prepared by Tapan K. Chatterjee, extension 2771.

Photograph 1: Position of temperature monitoring thermocouples, wires,

and partially charred purge dam paper and glue are shown.

AICK~veS5 A

(a)

-rucuss(b)

Photograph 2a-d:

1 4,

kc)

r

Irregular austenite grains and etch pits in 304 SS pipes with paper and glue on its id surface. The specimens

(a) 12 mm from bottom; (b) 7 mm from top; (c) 12 mm from top; (d) 9 mm from top were etched with 10% oxalic acid. Note the thickness of paper/glue layer as indicated on the pictures. 10OX

/~ I.

' C

44

*1

p

I,

A

1.~~

(c')

ka)k D)

Photograph 3a-d: Equiaxed austenite grains and etch pits in 304 SS pipes with paper and glue on id surface. The specimens (a) 12 mm from bottom; (b) 8 mm from top; (c) 10 mm from top; (d) 10 mm from top were etched with 10%

oxalic acid. Micrographs were made adjacent to id surface. 50OX

(C)

10

Figure la-b: Sketch showing (a) as-received specimen indicating (b) Longitudinal section through the paper/glue on the markings as top and bottom of the specimen.

the, dimensions; the pipe. Note

FTA

q. ~ Ld

N-

Top

Bottom


SINGLETON MATERIALS ENGINEERING LABORATORY

CHEMICAL ANALYSIS TEST REPORT

ATTACHMENT 10 SME QCP-8

Rev 2

Material Type

Lot No., 1. D.

Specification

Source

To: C. E. Ro

From: W. i. Ch.

Project: Bellef on

Report No.:

Date: 1-20-3

Purge Dam Residual

oerts, W11C114 C-K

ildres, SHE-K

te Nuclear Plant Purge Damo

Chloride, fluoride content (leachable)

Paul Guthrie

Results of the requested chemical analysis are as follows:

Leachable-chloride - 488.0

Leachable fluoride - <0.1

cc: NE S, W5B63 C-K

Tested by

Analy t icalhemist

Supervisor

TVA 22236 (CONST-12-80)

Date

Date

Date

ATTACHMENT D

FINAL REPORT TO NONCONFORMANCE 1725

ENCLOSURE BELLEFONTE NUCLEAR PLANT UNITS 1 LND 2

INSOLUBLE GLUE USED FOR ?URGE DAMS UN STAINLESS STEEL ?IFING NCR 1725

BLED-50-438/82-27, BLRD-50-439/82-24 10 C7R 50.55(e) FINAL REPORT

Descriotion of Deficiency

Some glue used in installation of purge. dams in stainless steel piping appeared insoluble during flushing activities, and =inor glue residual remains in piping at purge dam locations. This problem was anticipated during the resolution of noneonformance report (NCR) 835. The dispositionof NCR 835 directed discontinuing the use of Elmers Glue-All and recomended using Elmers School Glue. The insoluble glue residual has been identified as Elmers Glue-All used before NCR 835 and Elmers School Glue that has been affected by heat from welding activities. When purge dams are located too close to the welds, the currently used and normally soluble Elmers School Glue will char and become much less soluble.

Safety Imnlications

It has been determined through tests and analyses described below that no condition adverse to the safe operation of the plant exists. This conclusion is based on the following observations:

1) The purge dams will not cause stress corrosion cracking of the pipe.

2) Very little purge dam residual remains on the pipe wall after preoperational flushing. The residual remaining will all dissolve during plant operation. Solubilized purge dam :aterial is not harmful to the systems. Any particles that may break loose before dissolution is complete will not obstruct any piping or instrument lines.

Corrective Action

Based on the attached supporting information, TVA has concluded that glue residual left in piping systems will not cause a safety problem. Laboratory tests have shown that even the glue that was initially thought to be insoluble will dissolve. Flushing of systems thus far has shown that demineralized water flushing can achieve removal of enough of the purge dam residue so that the possibility of large pieces breaking loose is highly unlikely. TVA will revise the acceptance criteria for proof flushing particulates to allow purge dam particles up to 1/8-inch in any dimension. This revision will be accomplished by November 8, 1982.

In addition, purge dam residual on the pipe wall will be acceptable provided that the system has met the proof-flush acceptance criteria. The reactor coolant pump seal water injection-line in the Makeup and Purification System will be flushed with acetic acid to remove as much of the purge dam residue as possible. This will be accomplished by October 15, 1983. TVA has revised the welding specificatices to ensure that purge dams are placed far enough from the weld to prevent charring of the glue. TVA has also increased welder awareness that substitution of the specified Elmers School Glue is not permitted. No other TVA nuclear plants are affected by this problem.

ATTACHMENT

SUPPORTING INFORMATION FOR NCR 1725

Metallurgical Testing

Metallurgical testing and chemical analysis has shown that residual purge dam materials remaining in contact with 304 stainless steel will have no detrimental effects on the piping material during operation of the plant.

The Dissolvo Water soluble purge paper (WLD-60) contributes virtually all of the halides present in the purge dam residue. Specific ion tests have shown leachable chlorides in the range of 170-200 parts per million.

Tests show that purge dam materials closer than 3/ 4 -inch from the edge orf a weld reach a temperature of approximately 6000 F. At this temperature the material carbonizes to the extent that it flakes off much the same as food in a self-cleaning oven, and subsequent flushes remove the flaking material.

T4o pnt,.ntial modes of cracking have been addressed:

1. Stress Corrosion Cracking (SCC)

The purge dam residue is a minimum of 3/4-inch from the edge of the weld. This is beyond the distance at which residual stresses from welding are present. In the absence of tensile stress, SCC does not occur.

2. Intergranular Stress Corrosion Cracking (IGSCC)

The heat affected zone (HAZ) of the weld extends to a maximum of approximately 3/16-inch from the edge of the welds. As stated previously, the purge dams are located a mini=um of 3/4-inch from the weld and, therefore, the potentially aggressive environment' is not present in the HAZ.

Additional tests performed at TVA Singleton Laboratory determined that no har=ful effects should be expected even if the purge dam materials were left in contact with the base aterial. Samples of glue with added chloride levels of over 1000 ppm were baked on pipe samples and autoclaved at 1500 F and 5500 F in borated water. After 24 hours virtually all chlorides were leached from the glue at both temperatures. The 304 stainless base materials were subsequently examined microscopically -for corrosive effects.

After 96 hours of exposure there was no apparent attack. Because virtually all chlorides leach out of the glue after 24 hours of exposure, TVA anticipates no adverse effects from the relatively small amount of material remaining.

I.

Attachment Page 2

TVA can anticipate no harmful effects on the stainless steel pipe as a result of purge dam residuals remaining in contact with the stainless steel pipe-during system operation.

Acetic Acid Testing and Flushing

Laboratory testing was performed to deter4=- what solvents are available that could be used to remove the glue from the pipe. Testing showed that acetic acid was the most promising solvent. Acetic acid aided in the removal of the noncha-rred glue; however, it did not have an appreciable effect on the charred glue. The second interim report on NCR 1725 stated that acetic acid would be tried out on a system that had not been previously flushed. Since there were no systems available that had not been flushed, the trial was run on the Reactor Building Spray System (with the exception of the spray headers and the sodium hydroxide tank and piping).

The Reactor Building Spray System bad been previously flushed with water, but removal of a flanged spool piece. revealed ecocharred purge dam resilual on the pipe all. Thus the pipe interior could be visually inspected before and after the acetic acid flush. The system was flushed with 5 pergent acetic acid for approximately 24 hours at temperatures up to 145 F. Inspection of the piping after the acetic acid flush showed that most of the purge dam residuals had been * removed from the pipe wall.

Autoclave Tests

Autoclave testing was performed to determine what effect high temperate:r water will have on charred glue since it is the most insoluble. Stainless steel coupons were prepared using both Elmers Glus-All and Elmers School Glue. Coupons were baked in an oven at 400 F and 5000 F to simulate purge dams that were placed too close to the welds. Half of the coupons representing all of the above conditicns were soaked in acetic acid to simulate acetic acid flushing of the piping systems.

The coupo=s were placed in the autoclave which contained berated water representative of reactor coolant. The autoclave was operated at temperatu-es ranging from 200 F to 500 F to identify temperature effects cn the glue. The test results show that the charred glue will dissolve, and that the autoclave temperature is the only variable hat has an effect on the dissolution rate of the charred glue. At 200 aF about 6 percent of the charred glue dissolved in 90 hours. At 300 Fs 19 percent of the charrea glue dissolved in-78 hours; at 4000 , 84 percent of the charred glue dissolved in 51 hours; and at 5000 F, over 93 percent of the charred glue dissolved in 40 hours.

These results show that given enough time, the glue deposits will eventually dissolve. The results also show that any glue particles that get into te reactor will dissolve in the reactor, since it operates at 600 F.

.

Attach=ent Page 3

Deieralized Water Flushing

Several systems have been flushed with demineralized water to date.

These include the Spent Fuel Cooling and the Reactor Building Spray

Systems. Three flow paths on the Spent Fuel Cooling System were

flushed with =heated demineralizer ater. One flow path could not

meet the acceptance criteria of 1/32-inch by 1/16-inch pafrticle size.

However, the particleg were less than 1/8-inch. The flow path was

then flushed with 180 F water. After ihe hot water flush, the

acceptance criteria could still not be met, even though the particles

being detected were still less than 1/8-inch. Spool pieces were

removed so that the pipe interior could be visually-'examinfed. Reactor

building spray train B was also flushed with cold demineralized water

before the acetic acid flush. The path was flushed to the 1/32-inch

1/16 inch particulate acceptance criteria with demireralized water.

Inspection of the pipe interior after the flush showed some noncharred

purge dam glue ridges in the pipe. Flushing of these and other flow

paths has demonstrated that the systems can be flushed to a point where only tightly adherent glue ridges are left in the pipe and that

only small particles break loose from these ridges during system

operati'o..

Safety Analysis of Particulates

All of the systems were analyzed with respect to problems which could

be caused by particulates breaking loose from purge dam residuals

during plant operation. The analysis was based on the assunption that

glue particles up to 1/8-inch could be present in the operating syste=s. Based on this analysis, plant safety will not be sompromised

with glue particles up to 1/8-inch present in the Waste Disposal (WD), Chemical Addition and Boron Recovery (CA&3R), Reactcr Building Spray

(RBS), Core Flooding (CF), Decay Beat Removal (DER), Spent Fuel Pool

Cooling and Cleanup (SF?CC), and Makeup and ?urification (Mu&?)

Systems. ?umps in the RBS, DHR, SFPCC and MU&? Systems are equipped

with cyclone separators in the seal water supply so that particles in

the seal water would be removed. before getting to the pump seals. The

water in instrument sense lines is stagnant; therefore, it is highly unlikely that purge dam particles could find their way into instrument

lines or cause problems.

ENCLOSURE 3

TENNESSEE VALLEY AUTHORITY KNOXVILLE. TENNESSEE 37902

W7C126, 400 West Summit Hill Drive

February 14, 1983

Mr. Steven D. Weinman Nuclear Engineering Administrator Codes and Standards Division The American Society of Mechanical Engineers 345 East 47th Street New York, New York 10017

Dear Mr. Weinman:

ANSI N45.2.1-1973, SECTION 3.1.2

We are writing to request clarification of the intent of wording used in the subject standard as related to Class B cleanliness criteria, specifically the wording used in section 3.1.2. The subject standard has been incorporated into all TVA cleaning procedures for nuclear plants with the intent to comply with these standards. Recently, TVA's interpretation of the subject standard has raised some questions.

Background

When flushing is the only practical means for determining system cleanliness, Class B systems which have been flushed to the acceptance *criteria specified for proof flushes are observed to .occasionally contain some remaining particulates and debris deposited at points of stagnation exceeding the acceptance criteria which the flush met. This observation is made when flush paths are opened for service some time after preoperational flushing. TVA believes that it is not unusual to find some particulates or debris in a complex flush path, particularly in the 1ev points of the flush path and occasionally lodged in crevices. TVA also believes that this situation is not necessarily a reflection on the effectiveness of the flush. Furthermore, TVA believes that extending or repeating previously proofed flushes will not materially improve this situation (e.g., lodged material will not necessarily dislodge, and some types of particulates will never flush out of the system).

Question 1

When flushing is the only practical means for determining cleanliness, does a 20-mesh or finer side stream cartridge filter, or equivalent, connected to a 1- or 2-inch drain line near the end of a flush path for once-through flushes satisfy the intent of ". . . filter or equivaltnt installed on the outlet of the cleaning circuit?"

An Equal Opportunity Employer . . . ....... ...

2

Mr. Steven D. Weiman February 14, 1983

Reply 1

Yes, provided the water that passes through the cartridge filter is reasonably representative of the process flow.

Question 2

When flushing is the only practical means for determining cleanliness, does a 20-mesh or finer side stream cartridge filter, or equivalent, connected to a 1- or 2-inch drain line any place in the flush path for recirculating flushes satisfy the intent of ". . . filter or equivalent installed on the outlet of the cleaning circuit?"

Reply 2

Yes, provided the water that passes through the cartridge filter is reasonably representative of the process flow.

Question 3

When flushing is the only practical means for determining cleanliness and the system has been flushed at.normal design velocity and the evaluation of the particulates on the filter (or screen) establish that the acceptance criteria has been met, is it a requirement of N45.2.1 that the system be opened and accessed to perform a visual examination of low spots, dead legs, and components?

Reply 3

No.

Ouestion 4

If, in routine maintenance of components such as pumps and valves, the covers are removed and particulates are discovered in the internal system

. cavities, which exceed the size of particulates which are acceptable for . establishing prior system cleanliness, does the flush become invalid and

have to be repeated?

4b.

3

Mr. Steven D. Weinman February 14, 1983

Reply 4

No, the proofing of the system flush reported material which was in transport in the flush water. Any debris retained in low spots, crevices, stagnation points, and dead legs are not considered part of the cleanliness evaluation. If debris is not removed by system flushes at normal flow, it would not be expected to be transported during plant operation.

Prudent engineering practice would direct removal of debris of the nature described above whenever found.

We would appreciate your most urgent attention to this inquiry as construction of one of our nuclear plants is being delayed pending resolution of this issue.

Very truly yours,


3 C. A. Chandley, Chief Mechanical Engineering Support Branch

4..

Tennessee Valley Authority Mechanical Engineering Support Branch W7C126, 400 Wst Summit Hill Drive Knoxville, TN 37092

Att: C. A. Chandley, Chiet

SUBJECT:

REFERENCE:

Gentlemen:

ANSI/ASME N45.2.1-1973, Sec. 3.1.2

Your letter of February 14, 1983 ASE File # QA 83-2

Our understanding of the questions in your inquiry, and as follows:

our replies are

Question 1: when flushing is the only practical means for determining cleanliness, does a 20-mesh or finer side s tream cartridge filter, or equivalent, connected to a 1- or 2-inch drain line near the end of a flush path for once-through flushes satisfy the intent of "...filter or equivalent installed.on the outlet of the cleaning circuit?"

Reply 1: Yes, provided the water that passes through the cartridge filter can be demonstrated to be representative of the process flow.

Question 2: When flushing is the only practical means for determining cleanliness, does a. 20-mesh or finer side stream cartridge filter, or equivalent, connected to a 1- or 2-inch drain line any place in the flush path for recirculating flushes satisfy the intent of "...filter or equivalent installed.on the outlet of cleaning circuit?"

Reply 2: Yes, provided the water that passes through the cartridge filter can be demnnstrated to be reoresentative of the process flow.

ASME procedures provide for reconsideration of this interpretation when or if additional information is available which the inquirer believes might affect the interpretation. Further, persons aggrieved by this interpretation may appeal to the cognizant AS ME committee or subcommittee. As stated in the foreword of the code documents. ASME does not "approve,""certify," "rate." or "endorse" any item, construction, proprietary device or activity.

The American Society of Mechanical Engineers1 Uiiited Engineering Center * 345 E. 47th St., New York, N.Y. 10017 * 212-644-7722 * TWX-710-581-5267

June 06, '1983

'I

Tennessee Valley Authority Mechanical Engineering Support Branch w7C126, 400 West Summit Hill Drive Knoxville, TN 37092 Page 2 of 2

Question 3: When flushing is the only practical means for determining

cleanliness and the system has been flushed at normal design velocity

and the evaluation of the particulates on the filter (or screen) esta

blish that the acceptance criteria has been met, is it a requirement

of N45.2.1 that the system bb opened and accessed to perform a visual

examination of low spots, dead legs, and components?

Reply 3: No, under the conditions of the standard that flushing

is the only practical means of determining cleanliness.

Question 4: If, in routine maintenance of components such as pumps

and valves, the covers are removed and particulates are discovered

in the internal system cavities, which exceed the size of particulates

which are acceptable for establishing prior system cleanliness, does

the flush become invalid and have Eo be repeated?

Reply 4: No, the proofing of the system flush reported material whiich

was in transport in the flush water. Any debris retained in low spots,

crevices, stagnation points, and dead legs are not considered part of*

the cleanliness evaluation. If debris is not removed by system flushes

at normal flow, it would not be expected to be transported during plant

operation. Prudent engineering practice would direct removal of debris

of the nature described above whenever found.

Very truly yours,

Steve Weinman, Secretary Nuclear Quality Assurance Committee (212) 705-7025

SW: CC

&P em"c 6 V/K39'6. 400 Chestnut Street Tower II

December 12, 1983

U.S. Nuclear Regulatory Commission Region II Attn: Mr. James P. O'Reilly, Regional Administrator 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303

Dear Mr. O'Reilly:

In accordance with the provisions of 10 CFR 50.54(a)(3)(iv), enclosed is Revision 7 to TVA's Topical Report, TVA-TR75-1A, "Quality Assurance Program Description for Design, Construction, and Operation of TVA Nuclear Power Plants." TVA has decided to distribute Revision 7 before the NRC review has been completed because the new TVA quality assurance program under the TVA Office of Quality Assurance is being implemented, and the program description contained in Revision 7 is needed by TVA and NRC staff. This submittal has been discussed with and concurred in by Charles M. Upright of your staff.

Revision 7 is a major change to the TVA Quality Assurance Program description. The topical has been reformatted to be consistent with the description of TVA's integrated quality assurance program for design, construction, and operation. The major format changes have been the consolidation of all organizational descriptions into section 17.0 and the relocation of all figures and tables to the appendices. Additionally, the organizational descriptions have been updated to provide a consistent level of detail for the various TVA organizational units, and portions of the section 17.1 and 17.2 program descriptions have been revised to provide a more accurate description of our current program and practices.

Revision 7 review by your staff, as submitted to you by my letter dated July 11, 1983, has not been completed. Consequently, the proposed change to table 17D-1, sheet 1 (exception to ANSI N45.2.1) has been deleted until NRC review has been completed. Additionally, exceptions to ANSI N45.2.12, items 4.4 and 4.5 in table 17D-3, sheet 8, have been deleted until NRC review has been completed. Three editorial corrections to the review draft were made, which are:

1. Revision bars have been added beside Regulatory Guide 1.54 on sheets 7 and 8 of table 17D-1 and on sheets 7 and 8 of table 17D-2. Regulatory Guide 1.54 was added to those tables-in Revision 7 but the revision bars were accidently omitted. Also, the Regulatory Guide 1.54 revision and date were added to sheet 7 of table 17D-2 because they were accidentally omitted.

2. A paragraph has been removed from item M on sheet 7 of table 17D-3 to correct a typographical error. This paragraph was accidentally duplicated from another sheet and is unrelated to item M.

-2

Mr. James P. O'Reilly December 12, 1983

3. Sheet 2 of table 17E-1 has been revised to include the Construction Responsibility Descriptions Manual which was inadvertently omitted from the submitted version of Revision 7. Sheet 3 now includes material displaced from sheet 2 by the revision.

The results of your review of Revision 7 will be incorporated either into an amended Revision 7 or a Revision 8, as appropriate.

If you have any questions concerning this matter, please get in touch with D. L. Lambert at FTS 858-2733.

Very truly yours,



DLL:TAS Enclosure cc (Enclosure):

Document Control Desk (40) U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Director of Office of Inspection and Enforcement

ATTN: Mr. Walter P. Haass, Deputy Branch Chief Quality Assurance Branch


cc: ARMS, 640 CST2-C (Enclosure submitted under separate cover) J. W. Anderson, M155G MIB-K H. N. Culver, 249A HBB-K E. J. Ford, NRC Resident Inspector, Sequoyah (Enclosure) H. J. Green, 1750 CST2-C T. Heatherly, NRC Resident Inspector, Watts Bar (Enclosure) A. T. Mullins, 403 KB-C G. Paulk, NRC Resident Inspector, Browns Ferry, (Enclosure) J. A. Raulston, W10C126 C-K H. S. Sanger, Jr., E11B33 C-K F. A. Szczepanski, 417 UBB-C J. D. Wilcox, NRC Resident Inspector, Bellefonte (Enclosure) J. L. Williams, 1000 CUBB-C (ATTN: R. H. Sunderland)

A7 ~3 O0 003

1900 Chestnut Street Towe r TI

otobnr ?0, 1nR3

U.S. Nuclear flexulator7 Commission Repion IT Attn: Mr. James P. O'Reilly, Regional Administrator 101 Marietta Street, TW, Suite 2900 Atlanta, Georgia 30303

Dear Mr. O'Reillv:

BEL1LF0Y4TE NUCLEAR PLANT UNITiS I MND 2 - ISOLT3BLE GLUF U5ED FOR PUPME DAMS -IN STAINLEMSS STIZL PIPIG - nLD ;048/P-7 SUPPLE%,TNTAL I'INAL REPORT

As discussed with NRC-OTF Insvector P. F. Freadrickson on October 1!4, 1181, the date of October 15, 10111 for completion of corrective actions indicated in our final report on this matter would not be m~et, This is due to changes in the overall 30h Mules for these activities and reassig~nment of Vmanpower.Th crrective action on this "itter will be ooileted bv MAarch 10,, Q1P.

If you hnive any questions, please get in touch with R. H,. Shell at

Fl'S ~Very' truly yours,

TNNESSEE VALDLvY AUTHORTTY

L. M. Hills, ,Ianager Nuclear Licensing

cc: 11,r. Richard C. DeYoung, Director Office of Inspection and 1Tnforeement U.S. Nuclear Re~ulatorv Commission W-Rhinton, D.C. 205;

Director of ?luclear Reactor !Rem-lation Attention: !41. n~. Adensam, Chief

- YcensinR 13ranch To. It Division of Licensinst

U.S. 'luclear Perulatorv Commission W~ashington, D.C. ?0555

-~34O+4/ Orrp

A

-2-

U.S. Nuclear Regulatory Commission

RHS:KM:LHB cc: ARMS, 640 CST2-C

J. W. Anderson, M155G MB-K L. S. Cox, Bellefonte H. N. Culver, 249A HBB-K H. J. Green, 1750 CST2-C

COORDINATED: EN DES/Rowe, Love

October 20, 1983

R. J. H. F. J.

L. Lumokin, 401 UBB-C (2) A. Raulston, W10C126 C-K S. Sanger, Jr., E11Bjq C-K. A. Szozecanski, 220 101B-C D. Wilcox, Bellefonte-NRC

May 3, 1984Director of Nuclear Reactor Regulation Attention: Ms. E. Adensam, Chief

Licensing Branch No. 4 Division of Licensing


Dear Ms. Adensam:

In the Matter of the Application of' Tennessee Valley Authority

) -)

Docket Nos.

As discussed with NRC representatives during an April 2, 1984 telecon, we are formally transmitting a copy of our position concerning the possible blockage of instrument lines by the particles and the likelihood of stress corrosion cracking in the stainless steel piping due to the purge dam material. Enclosed is a copy of our response to these concerns with attached copies of supporting documentation.

If you have any questions concerning this matter, please get in touch with W. T. Watters at PTS 858-2691.

Very truly yours,



Sworn dss ed before me

Motary Publio MJyCommission Expires

Enclosure cc: U.S. Nuclear Regulatory Commission (Enclosure)

Region II Attn: Mr. James P. O'Reilly Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30303

RE-PeaewJcz 10 o

50-438 50-439

g{fr~Z~7c2A..7 340503 007

400 Chestnut Street Tower II

1* -

-2

U.S. Nuclear Regulatory Commission May 3,.1984

:KM:LHB cc (Enclosure):

ARMS, 640 CST2-C J. W. Anderson, M155G MIB-K E. A. Belvin, 109 MPB-M J. A. Coffey, 1750 CST2-C H. N. Culver, 249A HBB-K G. W. Killian, 401 UBB-C (2) J. A. Raulston, W10C126 C-K H. S. Sanger, Jr., E11B33 C-K F. A. Szczepanski, 220 401B-C Resident Inspector, Bellefonte-NRC

COORDINATED: EN DES/SLove

-I ENCLOSURE

BELLEFONTE NUCLEAR PLANT UNITS 1 AND 2 INSOLUBLE GLUE USED FOR PURGE DAMS IN STAINLESS STEEL PIPING

SUPPLEMENTAL INFORMATION FOR NRC-NRR EVALUATION

Below is TVA's response to concerns raised by Paul Woo as discussed with him on April 2, 1984.

1. Instrument lines are different from "dead legs" with respect to tendency to trap flow transported particles. TVA has referred to nonflowing branch lines (valved out, or blind flanged or capped off) as "dead legs." Instrument lines, on the other hand, are small diameter (3/8-inch outside diameter) tubing. The potential for dropping off flow transported particles at the branch connection of a dead leg is much greater than at an instrument line connection because of the typical size and geometry of each. Dead legs can be any size and located anywhere. In contrast, the instrument line connections on process pipes are comparatively small, and at BLN are located on the side (not the bottom) of the pipe. Particles could not "drop" into the instrument line branch connection during process pipe flushing or normal operation. Since the instrument lines are stagnant during normal operation and isolated at the root valve during process line flushing (usually the tubing is not yet installed), virtually no migration of particles is expected beyond the immediate vicinity of the branch connection. We also note that the instrument lines are flushed after the process line is flushed. Following the flushing of the instrument lines, there will only be flow in them when they are bled during maintenance. If a blockage occurred as a result of this flow, it would be noticed and corrected during the maintenance activity.

2. TVA does not believe that the small amount of purge dam material left in the piping will cause stress corrosion cracking for the following reasons:

a. There is not enough purge dam material in the systems to affect water chemistry. We have determined (refer to attachment 1) that if all of the purge paper that has been purchased for BLN to date were put into the reactor coolant system (RCS), the increase in the chloride level of the reactor coolant would be less than 1.0 ppm (note that the chloride limit of ANSI N45.2.1 is 1 ppm). This is a very conservative estimate because much paper was wasted in the process of making the purge dam, the paper was used in both units 1 and 2 (the calculation provided in attachment 1 is based on the RCS of one unit), and most of the paper was flushed-out of the sytems during preoperational flushing.

b. Flushing is performed with demineralized water. TVA procedures require that initial and final flush water be analyzed and must have a chloride concentration less than 0.15 ppm.

c. Any purge dam residue remaining on the wall of the pipe is not in the sensitized weld area.

d. Flushing is expected to leach most of the chloride from the residue that remains on the wall of the pipe. Testing by TVA's Singleton Lab has shown that more than 80 percent of the

chloride leaches out into ambient temperature demineralized water in 24 hours, and that more than 96 percent leaches out if a second leach is performed with fresh water. Attachment 2

documents the results of the Singleton Lab tests.

e. During hot functional testing and normal plant operation, the oxygen concentration in the reactor coolant will be reduced to less than 0.1 ppm with hydrazine before the temperature is raised above 250 0F (refer to B&W Test Specification 5000 Reactor Coolant System Test; B&W Operating Specification 0132 - Plant Startup; and B&W Operating Specification 11-01 - Plant

Limits and Precautions).

* -ATTACHMENT 1 PAPER PURE CHLORIDE CONCENTRATION CALCULATONS

Purpose

Estimate the increase of the chloride concentration in the reactor coolant system if all purge paper that has been purchased for BLN were

placed in the reactor coolant system just prior to hot functional testing.

Given

1. To date, 88 rolls (approximately 1,600 lbs) of purge paper have been purchased for BLN.

2. Volumes: Reactor coolant piping - 40,800 gals.

Steam generator (primary'side) - 30,500 gals.

Reactor coolant pumps

Total

- 1,200 gals.

- 72,500 gals.

Assumptions

1. The volume of the reactor vessel is assumed to be 0. The volume of the vessel without internals is 43,100 gal. The volume with internals is not immediately available. Therefore, to be conservative, it is assumed to be 0.

2. The chloride concentration of the glue used to install the purge dams is negligible in comparison with the purge paper and assumed to be 0.

3. The chloride concentration of the purge paper is 250 ppm.

Computations

Amount of Cl in the purge paper:

(1600 lb paper) ( 250 lb Cl ) 0.4 lb

106 lb paper

Cl in the paper

Amount of water in the reactor coolant system:

(72,500 gal)(8.34 lb/gal) = 604,650 lb water

Concentration of Cl in the water:

(0.4 lb Cl )( 1 ) = 6.6 x 107 lb Cl per lb H20

604 ,650 lb H20

or 0.66 ppm Cl in the water

Summary of Results

If all of the purge paper that has been purchased for BLN had been placed in the reactor coolant system just prior to hot functional testing, the Cl- concentration of the reactor coolant would have increased by approximately 0.66 ppm due to the CL- in the paper.

.YA <c..s.4.*5 ATTACIIENT 2 S"E'84 O405 002 CNI:D ,TATES GOL ETNMZN7

Mein7o r7 a d u inm TENNESSEE VALLEY AUTHORITY

C. E. Roberts, Supervisor, Codes, Standards, and Materials Section, Wi1C148 c-K/

W il W. H. Childres, Supervisor, higlrtb n-~Materia-Egin eering-taboratory, SME-K

DATE April 5, 1984

SUBJECT: BELLEFONTE NUCLEAR PLANT - EVALUATION OF PURGE DAM RESIDUE FOR TOTAL AND LEACHABLE CHLORIDES

- In response to request 3-27-84-4, tests have been performed to determine the chloride content of purge dam residue after incubation at ambient temperature (70 to 75 F) in stagnant water. Samples prepared to simulate purge dam-residue-were tested after drying at ambient temperature and after drying and heating at 4000F.

Samples dried at ambient temperature formed a uniform gelatinous mass when submerged in 150 ml of water. These samples would dissolve completely in larger volumes of water and consequently. all chloride would go into solution. Samples dried at 4000F softened but did not dissolve in water.

More than 80 percent of the chloride was leached within 24 hours from the

samples into quiescent ambient temperature water.

Exnerimental

Two pieces ("2.5 g each) of purge dam paper were coated on both sides with Elmer's School Glue and pasted together. Most of the samples were heated at 400oF for 1 hour; tests were also run on samples dried at room

temperature. The weight of paper, weight of glue after air drying, and weight of sample after the 4000 F drying were determined. Samples were cut in -1/2-in. to 1-in. pieces, immersed in 150-ml deionized water in plastic bottles, and incubated at ambient temperature (70 to 75 0 F) for initial times of 24, 48, or 72 hours. Second and third leaches were also done in 150-m1 aliquots of deionized water. The chloride ion content of the leach solutions was measured with a chloride selective ion electrode.

txi

V7~~

C. E. Roberts April 5, 19841

BELLEFONTE NUCLEAR PLANT - EVALUATION OF PURGE DAM RESIDUE FOR TOTAL AND LEACHABLE CHLORIDES

Results

After 24 hours incubation in water at 70 to 75 F, samples dried at ambient temperature were completely solubilized, i.e., the sample plus water was a fairly homogeneous gelatinous mass. - Since the entire sample dissolved, removal of chloride from this kind of material on a pipe surface is obviously complete.

The glue plus paper samples dried at 400oF to simulate heated purge dam residue turned dark brown and no longer immediately formed a gel on 0 contact with water. These samples softened when incubated in 70 to 75o water, but remained almost intact after 72 hours in quiet solutions. However, approximately 80 percent of the leachable chloride was removed from this residue in 24 hours.

There is little difference in the percent chloride removed among 24-, 48-, and 72-hour first leach tests, indicating equilibration between the paper and volume of solution present is nearly complete in 24 hours. In the presence of a larger volume of solution or in a stirred solution, more complete removal of chloride would be expected to occur during the first leach.

These tests show leachable chloride in heated purge dam 0 residue (paper plus glue) is reduced 80 to 90 percent by a 24-hour, 70 F immersion in a limited amount of water. The results show a 96 percent or greater removal of chloride occurs after a second leach.

W. H. Childres

CAC:ASY Attachments cc (Attachments):

MEDS, W5B63 C-K

Principally prepared by Carey A. Chambers, extension 2771.

A14096.1

a. *

AMTENT TMPERATURE LEACP OF CpLORTnp RPOM PURGE DAM RESTDUE

SUMMAPY OP TEST DATA

70oF Dried Wt of Paper

*Glue

6.47 6.76 7.17 7.21

7.55 9.14 8.20 7.23

7.57 6.69 7.41 7.72

400 0F Dried Wt of Paper

4Glue

5.75 6.03

- 6.37 6.49

6.63 8.19 7.31 6.42

Percent CL Removed Leach 1 Leach 2 Leach I

Z4_1 _ U8 7 2 h ZL 7 z~ 206hj 168 h

82 83 90 88

88 91 89 90

6.84 6.08 6.69 7.01

17 15

6 8

1 -2 1

4 4

-8 6

.7

89 89 89 88

4 3 4 3

8 7 8 8

3 3 3 4

it Percent chloride removed was calculated from the measured volume and chloride content of leach solution after each leach. After the third leach, chloride content of the leach solution was near the level of the deionized water used. Comparison of these calculations with mass balance calculations (% recovery of total chloride added) shows agreement within experimental error.

L114096.3

Wt off

S

2 11

4

13

5 10

9 17

18 20 22 24

4.98 5.30 5.08 5.08

5.18 5.13 5.39 5.22

5.19 5.07 4.98 5.44

..

-

..

..

-

-

.

.

I

400 Chestnut Street Tower II

February 1, 1985

Director of Nuclear Reactor Regulation Attention: Ms. E. Adensam, Chief

Licensing Branch No. 4 Division of Licensing

U.S. Nuolear Regulatory Commission Washington, D.C. 20555

Dear Ms. Adensamt

In the Matter of the Application of Tennessee Valley Authority

. Docket No.) )

Enclosed herewith are 60 copies of Bellefonte Nuclear Plant Final Safety Analysis Report (FSAR) Amendment 24. This amendment incorporates miscellaneous FSAR text revisions.

An instruction sheet is included with each amendment for incorporating the revised material into the FSAR,

If you have any questions concerning K. Mali at FTS 858-2680.

this matter, please get in touch with

Very truly yours,

TEflNESSEE VALLEY ALTHORITY

W. h , Mamger L oensing a.d Regulations

vern o and subscri d efore me this -1ay of 1985

Notary Public My Commission Expiresp

Enclosure (60) oc: U.S. Nuclear Regulatory Comission

Region II -'

Attn: Mr. James P. O'Reilly Administrator 101 Marietta Street, NW, Suits 2900 Atlanta, Georgia 30323

EFL4485CE 11

L44 850201 800 ///LJ

50-438 50-439

0-10,90 111-7/

r

-2-

U.S. Nuclear Regulatory Commission

JRHS &1HB cc: NUC PR ARMS, 1520 CST2-C

J. W. Anderson, 255 SPB-K W. R. Brown, 102 ESTA-K E. A. Condon, 1750 CST2-C J. W. Hutton, 1760 CST2-C R. J. Mullin, 1350 CUBB-C (2)

COORDINATED: EN DES/LCecilia

February 1, 1985

A. M. Qualls, Bellefonte J. A. Raulaton, W10C126 C-K H. S. Sanger, Jr., E11B33 C-K F. A. Szozepanski, 220 401B-C Resident Inspector, Bellefonte-NRC K. W. Whitt, 249A HBB-K

I-

BLNP-23

be brought to the attention of the plant superintendent through normal supervisory channels. The deficiency reports shall be

reviewed by PORC, which will make recommendations to the plant

superintendent. Deficiencies resulting from inadequate design or

improper installation shall be referred to EN DES and CONST,

respectively, for resolution as described in the previous

section.

14.2.5 Review. Evaluation, and Approval of Test Results

14.2.5.1 Preoperational Tests

At the completion of each test, the test director and test

representatives shall conduct a field evaluation of the test

results. If the results meet the specified acceptance criteria,

the test director shall forward the data package for final

approval.

The EN DES test representative shall review each test data

package considering the adequacy of testing as actually

pertormed, comparison of test results with acceptance criteria,

and evaluation of all test deficiencies. The EN DES test

representative, with input from other EN DES organizations, shall

specify the corrective action for all remaining test deficiencies

and shall specify retesting or additional testing required

because of test deficiencies and subsequent corrective action.

U pon completion of the review and resolution of all test

deficiencies, the Chief of the Mechanical Engineering Branch of S EN DES or the Branch Chief or project manager of any. other cognizant EN DES organization shall certify by memorandum to the

plant superintendent that the system did functionally perform in

accordance with design requirements.

In addition to review by EN DES, all test results for BOW

supplied systems shall be reviewed by BW. The plant t

superintendent shall give the final approval for the results of

all preoperational tests.

All preoperational tests, with the exception of those

specifically designated to be conducted after fuel loading, shall

be completed and approved before the startup test program is

begun.

14.2.5.2 Startup Test Results

Field analysis of data for each major step of the startup test

program shall _be completed and approved by PORC and the plant

superintendent before progressing to the next step. For this

purpose, major steps will be considered to be precritical

testing, initial criticality and zero power testing, and the

11/5/82 14.2-11

BLNP-24

testing performed at each major power level (15%. 40%, 75%, and 100%). Any deficiencies noted during testing will be reviewed and resolved by PORC as described in Section 14.2.4. Copies of

all test data and analyses are distributed to B8W and reviewed within TVA by NUC PR. EN DES will review and has approval responsibility over test results from tests selected for review

as described in Section 14.2.3.2. The plant superintendent has

final acceptance authority over all startup test results.

14.2.6 Test Records

All test results, after formal approval, shall be filed in plant

files for future reference and retained for the life of the

plant.

14.2.7 Conformance of Test Programs with Regulatory Guides

The following regulatory guides are used as guidelines in the

preparation of test scoping documents, test instructions, and

administrative controls for the initial test program:

Regulatory Guide Number/Title

1.20 Comprehensive Vibration Assessment Program for Reactor Internals During Preoperational and Intitial Startup Testing (5/76)

1.30 Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electric Equipment (8/72)

1.37 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of WaterCooled Nuclear Power Plants (3/73)

Conformance

Conforms fully - A preoperational flow-induced vibration test will be performed on the internals of the prototype 205 F.A. plant. At this time, Bellefonte Unit 1 is expected to be the prototype 205 F.A. plant.

Conforms fully.

Conforms to the intent of the 24 regulatory guide with the following exception: Some low solubility glue was used for installation of purge dgMs, therefore, exception is taken to the ANSI N45.2 .1 acceptance criteria for particles and adherent residue resulting from weld purge dam materials. Documented in Bellefonte nonconformance report (NCR) 1725 0640.16

14.2-12

09 12.. 199T in:J? LINE o~s i.ni 1'~ c-f- H~ ~ ~H

\LN-NB-D053-0-HCG Rev DTD-032686

RO

Abstract

The problem is based on 88 ro

the volume of the reactor coo

82,886 gallons. Assuming the

250 ppm, it was determined th

for BLNP had been placed ir. t

testing, the chloride ion con

by approximately 0.60 ppm due

beer deduced that if small alv

water chemistry will be negl~

(for Rims use) RIMS accession number

860602B0074 44 '860 5 0

R2 R3 Statement of Problem

The purpose of this problem is to

demonstrate that the reactor

coolant chemistry will not be

affected if very small amounts of

purge dams remain in the systems.

Since there is no way of knowing

precisely how much purge dam

,residual might be in the systems,

a very conservative approach was

used.

ls (approximately 1,600 pounds) of purge paper, with

lant piping and pumps and steam generator taken as

chloride ion concentration of the purge paper to be

at if all of the purge paper that has been purchased

he reactor coolant system, prior to hot functional

Lcentration of the reactor coolant would have increased

to the chloride ion in the paper. Therefore, It has

ounts of purge dam remain in the systems, the effect on

Lgible.

This Calculation does not contain any

unverified assumptions.

please return original to Drouhard, W7 A64 C-K, Extension 2702.

PlM5 SL26 C-KI

09 2/187 11139 DNE 0 45 W11 190 C-K blt. bcitbb .U

TVAE CALCULATIONS

TITLE Purge Dam Paper LANT/UNIT

Chloride lon Calculation for StainleSS Steel Safety Systems LN Uci I

PREPARING ORGANIZATION E!bip6 IST MEB/HCC .u hlrd

NCHIPrACTItANT~iC& acht e CAL 4CUL ATION D deIgl IENTIFIERS Eat rn th m .IuItIost e 10ued, Prerst esur htteoiia )R~ceso

REVISION LOG

Purge Dam Paper Chloride Ion Calculation for Stainless DNE CalculGtions

Title: Steel Safety Systems Date

Revision DESCRIPTION OF REVISION Approved No.

1 This calculation was revised because of Engineering Assurance

audit deficiency 86-31-05. The original calculation was not

in accordance with the engineering procedure NEP-3.1. The

revision brings the calculation into conformance with the NE?.

The results of this calculation were not changed.

TVA 106245(4 055-4*7)

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Documents

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