05000346/FIN-2011012-01
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Finding | |
|---|---|
| Title | Unable to Locate Fatigue Analysis for Class I Valves |
| Description | The fatigue monitoring program is an existing program which, when enhanced, will be comparable to Section X.M1, Fatigue Monitoring, of the GALL Report. The fatigue monitoring program manages fatigue of select primary and secondary components, including the reactor vessel, reactor internals, pressurizer, and steam generators by tracking thermal cycles. The program provides an analytical basis for confirming the actual number of cycles does not exceed the number of cycles used in the design analysis and the cumulative usage is maintained below the allowable limit or that appropriate corrective actions are taken to maintain component cumulative fatigue usage below the allowable limit during the period of extended operation. During the application review, NRR staff raised concerns related to document discrepancies; the most-limiting locations may not have been analyzed; actual transient severity versus design transient severity; use of an inspection program versus a preventative action program; establishing program acceptance criteria; review of operating experience; and cycle counting. The concerns were documented in RAIs B.2.16-1 through B.2.16-7. In Letter L-11-166, which responded to RAIs B.2.16-1 through B.2.16-7, the applicant answered NRR RAIs and committed to enhancements to evaluate additional plant-specific component locations that may be more limiting than those considered in NUREG/CR-6260; provide for updates of the fatigue usage calculations if the allowable cycle limit is approached; and establishing acceptance criteria for maintaining the cumulative usage below the Code design limit of 1.0 throughout the period of extended operation. The inspectors reviewed revised program documentation and verified these enhancements were included. The inspectors also reviewed other program documentation, the existing program (including the transient status log from the most-recent outage), condition reports, and interviewed the applicants staff responsible for the program. The inspectors noted NRR, during their review of the application, had identified the licensee could not locate the fatigue analysis for Class I valves. This issue is a current licensing basis issue and is considered an Unresolved Item pending further review (URI 05000346/2011012-01) Unable to Locate Fatigue Analysis for Class I Valves. While not directly part of the fatigue monitoring program, during their review of the program, the inspectors noted that in LRA Table 3.3.1, Item 3.3.1-01, the applicant stated that, for steel cranes, fatigue analysis is a TLAA, and further evaluation is documented in LRA Section 3.3.2.2.1. In LRA Section 3.3.2.2.1, the applicant indicated that fatigue TLAA evaluations are addressed in Section 4. However, there is no discussion of fatigue TLAAs of steel cranes in LRA Section 4. The applicant issued OIN-378 to track completion of the changes required to the LRA and license renewal program documents in order to document disposition of steel crane cycles as TLAAs. While reviewing the existing program, the inspectors noted that in Attachment 3 of the program, for transient 30, the column Estimated Date to Reach Limit is marked as N/A. This is incorrect, as Pressurizer Spray Nozzle is a monitored transient. The applicant issued SAP Notification 600704256 to track the correction of this error. The inspectors concluded that implementation of the enhanced Fatigue Monitoring Program will provide reasonable assurance that the aging effects due to cyclic fatigue will be managed so that the program components will continue to perform their intended function, consistent with the current licensing basis, for the period of extended operation. |
| Site: | Davis Besse  |
|---|---|
| Report | IR 05000346/2011012 Section 4OA5 |
| Date counted | Sep 30, 2011 (2011Q3) |
| Type: | URI: |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71002 |
| Inspectors (proximate) | B Jose S Sheldon V Meghani A Stone J Suscoa Wilsond Kimble J Beavers J Maynen J Neurauter J Steffes L Jones M Bielby M Holmberg R Jones T Bilik T Go |
| INPO aspect | |
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Finding - Davis Besse - IR 05000346/2011012 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Davis Besse) @ 2011Q3
Self-Identified List (Davis Besse)
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