ML19345B219
| ML19345B219 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse, Farley  |
| Issue date: | 11/14/1980 |
| From: | Reid R Office of Nuclear Reactor Regulation |
| To: | Crouse R TOLEDO EDISON CO. |
| References | |
| TAC-10985, NUDOCS 8011260370 | |
| Download: ML19345B219 (14) | |
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uma UNITED STATES j
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NUCLEAR REGULATORY COMMISSION g
l WASmNGTON, D. C. 20556 s.,*.m /
November 14, 1980 P
-Docket No. 50-346 3,
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h Mr. Richard P. Crouse 3
Vice President, Nuclear N
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Edison Plaza 3o Toledo, Ohio 43652
Dear Mr. Crouse:
We have conducted a preliminary review of your submittal of May 15, 1980, in which you forwarded a revised Inservice Inspection Program for the Davis-Besse Nuclear Power Station, Unit No.1. As a result of our review, we have developed the questions and coments regarding your program con-tained in Enclosures 1 and 2.
Enclosum 1 contains coments regarding testing of pumps and valves, and Enclosure 2 contains comments on inspec-tions of piping and components. These comments will fonn the basis for a working session to be held at the Davis-Besse site on November 19-21, 1980, which has been previously arranged with your staff.
Following the working session, it will be expected that your program be revised as necessary to reflect revisions agreed to during the session.
We look fervard to meeting with your staff at the working session.
Sincerely,
'h//
W RolIert. Reid, Chief Operating Reactors Branch #4 Division of Licensing
Enclosures:
1.
Questions & Comments Re: Inservice Testing Pmgram 2.
Request for Additional Infonnation cc w/ enclosures:
See next page 8011:260 37 0
Toledo Edison Company cc w/ enclosure (=):
J-v Mr. Donald H. Hauser, Esq.
U.S. Nuclear Regulatory Conmission t-The Cleveland F'ectric Resident Inspector's Office Illuminatin; :ompany 5503 N. State Route 2 P. O. Box 5000 Oak Harbor, Ohio 43449 Cleveland, Ohio 44101 Director, Criteria and Standards Gerald Charnoff, Esq.
91 vision Shaw, Pittman, Potts Office of Radiation Programs (ANR-460) and Trowbridge U. S. Environmental Protection Agency 1800 M Street, N.W.
Washington, D. C.
20460 Washington, D. C.
20036 Leslie Henry, Esq.
Fuller, Seney, Henry and Hodge U. S. Environmental Protection Agencj 300 Madison Avenue Federal Activities Branch Toledo, Ohio 43604 Region V Office ATTN: EIS COORDINATOR Mr. Robert B. Borsum 230 South Dearborn Street Babcock & Wilcox Chicago, Illinois 60604 Nuclear Power Generation Division Suite 420, 7735 Old Georgetown Road Bethesda, Maryland 20014 Ida Rupp Public Library Ohio Department of Health 310 Madison Street ATTN: Director of Health Port Clinton, Ohio 43452 450 East Town Street Columbus, Ohio 43216 President, Board of County Commissioners of Ottawa County Port Clinton, Ohio 43452 Attorney General Department of Attorney General 30 East Broad Street Columbus, Ohio 43215 Harold kahn, Staff Scientist Power Siting Commission 361 East Broad Street Columbus, Ohio 43216 Mr. Rick Jagger Industrial Commission Statt of Ohio 2323 West 5th Avenue Columbus, Ohio 43216 Mr. Ted Myers Manager, Nuclear Licensing Toledo Edison Company Edison Plaza 300 Madison Avenue Toledo, Ohio -.43652
QUESTIONS AND COMMENTS CONCERNING THE TOLEDO EDISON COMP;4:
IN-SERVICE TESTING PROGRAM FOR DAVIS BESSE UNIT 1 Docket Nu.ber 50-346)
(Ref:
m 4
Davis Besse Unit No. 1
GENERAL COMMENT
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. 1.
Category A valves are defined as valves for which seat leakage is limited to a specific maximum amount in the closed position for fulfillment of their function.
2.
Th'e following Staff position on valves designated as Category A (or combination of categorie; such as Category AC) should be noted:
Those valves that perform both a pressure isolation and containment isolation function shall be leak tested to meet both Section XI of the applicable edition of the ASME Code and Appendix J of 10 CFR 50 requirements.
Those valves that perform a pres:;ure isolation function only shall be required to meet Section XI of the applicable edition of the ASME Code.
Those-valves that perform a containment isolation function only shall be required to meet Appendix J of 10 CFR 50.
PUMPS 1.
Review the safety related function of the diesel fuel oil transfer pumps to determine if they should be included in the IST program and tested in accordance with Section XI.
2.
The auxiliary feedwater pump speed should be measured in accordance with IWP 4400 of Section XI.
3.
The NRC staff has not approved revisions to section IWP of the code made by the Operating and Haintenance group. Therefore, inservice testing of pumps should be conducted in accordance with the 1977 3
edition and suntner 1978 addenda until such revisions are issued and approved by the staff.
VALVES A.
Main Steam Drawing 003
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1.
Valves ICS-38A and B must be exercised and timed unless specific relief is requested from the requirenent of Section XI.
2.
Review the safety related function of valves MS-731 and MS-732 to determine if they should oe included in the IST program and categorized C.
3.
If manual stop valves upstream of ICS-38A and ICS-388 exist as shown on the P&ID, these valves should be included in the IST program.
4.
Review the safety related function of valves MS-209 and MS-210 to determine if they should be included in the IST program and categorized C.
B.
Feedwater System Drawing 006B 1.
Do provisions exist to manually exercise valves SW-3 and SW-47 2.
Review the safety related function of the following valves to determine if they should be included in the IST program and categorized as indicated.
Category B Passive Category C CD-170 CD-189 C.
Steam Generator Secondary Drawing 007 l
1.
Are valves AF-599 and AF-608 accessible during power operation?
2.
Provide more detailed technical information on how valves AF-39, 43, 72, 73, 74, and 75 are full stroke exercised during refueling outages. Why can't these valves be exercised during cold shutdown?
D.
Makeua Water Treatnent System Drawing 010B 1.
Review the safety related function of OW-6831A and 68318 to determine if they should be categorized A.
E.
Station and Instrument Air Drawing 015 1.
Review the safety related function of the following valves to determine if they shc ld be categorized as indicated.
Categcry A Category A/C SA-2010 SA-502 IA-20ll IA-501 2.
Provide more detailed technical information why valve SA-2010 cannot be exercised during power _ operation and cold shutdown.
F.
Nitrogen Sucol,v..Orawing 019 1.
Review the Safety related function of the following valves to 4
determine if they should be categorized as indicated.
Category A Category A/C NN-236 NN-58 G.
Containment and Penetration Rooms Drawing 029A 1
1.
Review the safety related function of the following valves to determine if they should be categorized as indicated.
Category A Category A/C CV-5037' CV-209 CV-5038 CV-210 CV-5007 CV-5008 CV-5005 CV-5006 CV-5065 CV-5090 1
2.
Are the following valves designed to shut against Design Basis Accident differential pressure?
CV-5007 CV-5008 CV-5005 CV-5006 H.
Containment and Penetration Rooms Drawing 0292 1.
Review the safety related function of valve CV-50103 to determine if it should be included in the IST program and categorizec A.
2.
Review the safety related function of the following valves to determine if they should be categcrized as indicated.
Category A CV-5070 through CV-5079 4
CV-5010A, C, 0, and E CV-5011A, B, C, 0, and E 4
Category A Passive CV-343 i
I Cagegory A/C j
CV-5080 through CV-5089 CV-124 and CV-125 l
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I.
Reactor Coolant Orawing 030 1.
Retiew the safety related function of valves RC-240A and RC-2403 to determine if they should be categorized A.
2.
The staff position concerning RC-2A is as follows:
L Full stroke exercising should be performed during cooldown prior to achieving the water solid condition in the pressurizer and during cold shutdown prior to heatup.
Stroke timing snould be performed at each cold shutdown or as a minimum once each refueling cycle.
Fail safe actuation testing is permitted by the Code to be performed at each cold shutdown if the valves cannot be tested during power operation. This testing should be performed at each cold shutdown.
3.
What is the safety related function of valve RC-10.
J.
Makeuo and Purification Drawing 031 1.
Review the safety related function of the following valves to determine if they should be categorized as follows:
Category A Category A/C MU-33 MU-38 MU-242 MU-66A MU-3 MU-243 MU-668 MU-2A MU-244 MU-66C MU-245 MU-660
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MU-59A MU-598-MU-59C MU-590 1
2.
Provide a more detailed technical basis why valve MU-33 cannot be exercised during cold shutdown.
3.
Does exercising MU-3 during power operation cause a loss of pressurizer level control if it should f ail shut?
4..
Provide a detailed technical basis why valve MU-2A cannot be exercised during power operation and cold shutdown, i
K.
Decay Heat and Emergency Core Cooling Drawing 033 1.
Review the safety related function of the following valves to determine if they should be categorized as follows:
Category A Cat _egory A/C Category B/C DH-23 DH-87 DH-1B CF-23 HP-56 HP-32 DH-11 DH-88 DH-2735 CF-29 HP-57 HF-31 DH-9A HP-2A DH-2736 HP 48 HP-58 DH-98 HP-28 HP-2C HP-49 HP-59 DH-1517 DH-1A HP-2B HP-50 DH-10 DH-26 HP-51 2.
Would f ailure of valve DH-2733 or DH-2734 while testing result in a loss of redundancy or a limiting condition for operation?
3.
Is the valve identified as DH-18 in the valve testing program supposedtobeDH-1518? Should this valve be categorized A?
4.
Provide more detailed technical information how the following valves are full stroke exercised.
CF-28 CF-29 CF-30 CF-31 i
__ _ C 5.
Are means available to measure the pressure on the high pressure side of valves HP-2A, 28, 2C and 2D prior to exercising during power operation.
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6.
Review the safety related function of valves DH-14A and DH-14B to detennine if they should be categorized B.
c-7.'
Review the safety related function of the following valves to determine if they should be included
.'n the IST program and categorized as follows:
Category B Category C OH-13A DH-49 DH-13B K.
Emergency Core Cooling, Containment, Spray, and Core Flood, Drawing 034
'1.
Review the safe'ty related function of the f olicwing valves,to catermine if they should be categorized as folic;.s:
i Category A Category A/C CF-2A CF-15 CF-2B CF CF-5A CF-58 CF-1544
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CF-1545~
i CF-1541 CF-1542 CF-1530 CF-1531 SA-532 SA-533
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Component Cooling Water, Drawing 036 1.
Review the safety related function of the following valves to detenmine if they should be categorized as follows:
Category A Category B/C
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CC-1411B CC-151 CC-149 CC-1407B CC-152 CC-148 CC-15678 CC-153
-CC-147 CC-154 CC-150 CC-131 CC-135 CC-132 CC-136 CC-133 CC-137 CC-134 CC-138 t
2.
Is the valve identified in the program as CC-1573 supposed to be CC-1567B?
3.
Provide a mora detailed technical basis wny alves CC-1567A and CC-1567B canriot be exercised during cold shutdown.
M.
Reactor Coolant 3, stem Drawing 040A 1.
Review the safety related function of the following valves to determine if they should be categorized as follows:
Category A
. Category A/C RC-1719A RC-113 RC-1719B RC-229A RC-2298 RC-232.
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Category A i
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55-2358 RC-1773 A.
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1 N.
Review the safety related function of the following valves to
.l determine if they shculd be included in the IST program and f
categorized as follows:
Category B -
Catecorv 3 Passive I
SW-2927 SW-252 SW-2928 SW-253 SW-2929-l 3
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REQUEST FOR ADDITIONAL INFORMATION
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Davis-Besse Unit 1 ISI Program e
1.
Your ISI program lists the following components and inspections which are not in accordance with Section XI requirements:
Licensing Exam Code Code System Item No.
Performed Requirements Item Auxiliary 35-0 Surface on Surface on 25%
C5.10 "4edwater 36-0 10% of. welds of welds rage III-7 Decay Heat 27-3 No test Voluratric B9.10 Removal page III-12
& III-16 Main System 39-2B None Not known be-Secondary 40-2B cause submittal System does not indi-page III-21 cate normal operating temp-erature and pressure.
Reactor Cool-PZ-2 None Surface 89.20 ant System PZ-4 None Volumetric B9.10 page III-29 74C-0 Pressure Test Surface 89.20 and III-30 74C-1 Pressure Test Surface B9.20 Decay Heat 02552-6 Surface Volumetric C2.20 Cooler ISID shell-to-No. 33 flange Weld G Category C-B Your ISI proccam should be amended to reflect the Section XI requirements or a relief request with technical justification should be submitted.
2.
Your ISI program states that ASME Code Class 1, 2, and 3 components will be examined to the 19,77 Edition of Section XI including Addenda through Summer 1978. However,10 CFR 50.55a(b) takes exception to certain pro-visions of these Code Edition and Addenda. Paragraph 50.55a(b)(iv) state that appropriate Code Class 2 pipe welds in the residual heat removal system, emergency core cooling systems and containment heat removal systems shall be examined. The extent of the examination for these systems shall be
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. determined by the requirements of Table IWC-2520, Category C-F and C-G and paragraph IWC-2411 in the 1974 Edition and Addenda through Summer 1975 Addenda of Section XI of the ASME Code.
- Therefore, we will require that your ISI program include a representative samp-ling of welds and the proposed method of exanii.'ation for the ECCS, RHRS, and CHRS e-wel ds. The " chemistry control" provision contained in basis for exempting com-ponents from examination because practical evaluation, review and acceptance standards can not be defined. These safety related systems can not be completely exempted from volumetric or surface examination based on Section XI criterion for low operating pressure and tenperature or small pine diantter. One basis for selectino your representative sample should be components in sinilar plants have txperienced generic failures as idantified in ISE Sulletins.
3.
Yuur ISI program states that the accessible length of the reactor vessel lower head weld MX-171 to MK-181 will be examined.
Estimate the total weld length that can be examined, describe the measures required to comp' ate the examination of 100% of the weld and describe any alternative examina-tions.
In addition, for any other welds in Class 1 or Class 2 c&nponents where inspection requirements of Section XI cannot be met due to component design or geometric configuration restraints, we will require a request for relief from Code requirements. The relief should detail the reason for not complying with Code, the extent to which code requirements can be met and any additional examinations performed on the remainder of the compo-nents.
4.
Your program states that pressurizer support Item 154592E will be examined using surface methods. Since Section XI requires volumetric or surface examination as applicable, explain the reason surface examination is applicable.
Also, for any other Class I support components where Section XI allows the option of volumetric or surface examination, and a surface exanination was chosen, explain why a surface examination is most suitable.
5.
For Class 1 and Class 2 components and component supports certain 1977 Edition through Summer 1978 Addenda of Section XI examination requirement and acceptance standards are "In course of preparation." Since your program is based upon the 1977 Edition of Section XI where examination requirements or acceptance st?'dards are not yet prepared, ex' lain what acceptance standards and e>> Tination requirements you will use.
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