ML20093M351

Responds to Relief Request Item II.B.2.1 of Safety Evaluation Re Revised Inservice Insp & Testing Program. Alternative Testing & Optional Testing Techniques Discussed. Acceptable Method of Testing Will Be Evaluated

ML20093M351
Person / Time
Site:	Davis Besse
Issue date:	10/18/1984
From:	Crouse R TOLEDO EDISON CO.
To:	Stolz J Office of Nuclear Reactor Regulation
References
1084, TAC-57024, NUDOCS 8410220080
Download: ML20093M351 (4)

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Docket No.150-346 iotroo EDISON License No.'NPF-3 RCHARD P. COcuSE Serial No. 1084 vm. woo ux=,

1. """**28' October 18, 1984

, Director of Nuclear Reactor Regulation

Attention: Mr. John F. Stolz

' Operating Reactor Branch No. 4 Division of. Operating Reactors United States Nuclear Regulatory Commission

. Washington, D.C.

20555

Dear Mr..Stolz:

Toledo Edison Company submitted a revised Inservice Inspection (and testing) program on May 15, 1980 (Serial No. 616). By. letter dated May 5, 1982 (Log No.~ 979), your office informed us of the results of the review concerning welds, supports,'etc., and system pressure tests (Sections 3 and 4). In your letter dated May 18, 1984 (Log No. 1521),

_your office informed us of the results of your review of pumps and valves

.(Sections _1 and 2). Program amendments and supplemental information were submitted as Toledo Edison Company' letters lated as follows:

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December 15, 1980 (Serial No. 671)

March 31, 1981 (Serial.No. 702)

December 14, 1982 (Serial No. 882)

February 2,1983 (Serial No. 908)

April 29, 1983 (Serial No. 939)

June 2, 1983 (Serial No. 953)

'This letter is a continuance of these response actions and relates specif-ically to Relief Request Item II.B.2.1 of the Safety Evaluation by the

-office of Nuclear Reactor Regulation which accompanied your letter of May 18, 1984 (Log No. 1521).

We note your declared position that the High Pressure-Injection line check valves (HP-48, 49, 50, 51, 56, 57, 58 and 59) perform a prcssure isolation function. Furthermore, you requested Toledo Edison to develop a method to determine the condition of each valve and submit it for staff review by November 18, 1984. Your suggested methods were: pressure monitoring, leak testing, radiography and ultrasonic testing. It is further stated by your staff that if leak testing is selected as the desirable method, the valves in question be classified as A or AC and tested io accordance with IWV 3420:of_.the Code, f

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o THE TOLEDO EOISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEOO, OHIO 436521

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lAs required lin your staff's evaluation statement, Toledo Edison Company 1 hereto defines:a method ofl testing which is submitted as complying with'

, your- requirements. The original basis for the relief request is reiterated:

" Reverse flow / cycling during normal operation,' cold. shutdown and refueling is precluded by system designifor individual check

valves. . Upstream'of these valves are motor-operated, normally.

closed: valves which are designed and analyzed as seismic class I.

These motor operated valves HP-2A, B, C, and D are stroked and

, '. timed at cold shutdown. =The system normal operating pressure is

continually monitored in the Control Room by a high pressure alarm set. at : 375 'psig. =

ALTERNATIVE TESTING will be conducted during the 1984 Refueling Outage using leak detection methods ~to determine breakdown of the pressure

, isolation function of each pair of back-to-back check valves. The tests o- # will'be.' conducted during operating Mode 3 in association with pressure monitoring ofithe upstream volumes in the system.' ,

' The following valves will be declared -as either Category -A or AC until the 15th refueling cycle;-HP-2A, B, C, D, HP-22 and 23-(Reference P&ID-033) and LMU-169,:196, and 197 (Reference P&ID-031). These valves will be leak tested'during the.1984 Refueling Outage (Mode 5'or 6), and then at each-cold shutdown-(Mode 5)> lasting more,than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> but not more frequently

than once every three months.

It:also should be noted that;25% of the piping welds.between the Class 1 system;and the' Class.2' motor _ operated valves (a normally exempt system) were examined in compliance with IE Bulletin 79-17'as part of the ISI program.

U OPTIONAL TESTING TECHNIQUES are being explored in keeping with regulatory concerns expressed in the SER and : subsequent- conversations between Toledo Edison and the staff. - The : options. being considered individually. or -in

, ' combination are:

O 9Acous' tic Emission (AE) leak monitoring of the back-to-back check

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-The following actions would be required to conduct AE leak monitoring:

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a.. Operating : background' data will be required to provide for p, proper signal assessment at.each valve pair location. This

- requires the unit to be at operating pressure and temperature

.- (Mode 3).

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' License No..NPF-3 V 4 Serial No. ' 1084

Octoberi 18, 1984L Page'3,

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[b.' i Amock-up of the valve configuration will be needed to Sprovide calibration data. Material procurement, fabri-

' cation ofithe mock-up assembly, and test provisions need to be accomplished before actual test data can be generated, c.. Assuming AE testing can be proven from the mock-up arrange-ment. appropriate. teat equipment will needsto be procured,

' .' manufactured, and deployed for plant use.

2.- Radiography (RT), ultrasonic testing-(UT), and infrared (IR) evalua-tion'of the back-to-back check valves. ._

For'RT, UT, or IR testing, further' industry testing needs to be per-formed to-obtain base-'line information to prove these non-standard techniques as viable testing' alternatives without compromising code-

' requirements.

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'3. Line modifications with provisions for leak monitoring; i.e., addi--

tional~valvas or valve relocation.

For line modifications, design and analysis of this ASME Section III-

~ Class 1fpiping would need to be performed. Field verification would need to be done prior to any system design activity. Procurement of any new valves,1 piping and. pipe fittings (Class 1 are not shelf items).

.could easily incur a one year lead-time. Installation of new check

! valves inside containment between the. present back-to-back check valves and.the motor operated valves HP-2A, B, C, and D, with provision for a

. test. tap would' treat the existing two check valves'as a unit. The

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present stop valve checkTwould be used to' isolate'the line.to allow N . installation of the new valve. Installation of a test tap between the

-existing back-to-back check valves, due'to space restrictions, would-need to be welded into the-side of-the Class 1'stop check valve body.

This machining is non-routine and involves significant unknowns if-done~with the valve in line. Should the machining result in damage to the valve, a replacement could become a one. year lead time item.

. Davis-Besse Unit-l-is currently in a refueling outage scheduled for comple-

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. tion in late December, 1984. From the'above discussions, the Optional Testing Techniques would be: impractical and unrealistic to implement during the cur-

rent' refueling ~ activities.

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• ', _ Docket No.-50-346 License No. NPF-3

10. -Serial No. : 1084 -

October 18,1 1984-Page 4-L

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Toledo Edison willl evaluate' the Optional-Testing' Techniques, along~ with the Alternative Testing, to determine an acceptable' method of testing to meet the inservice inspection' requirements for this system.

Toledo Edison will submit a. report identifying the status of the alterna-tives under evaluation by March 31, 1985.

Very truly1yours.

- RPC:RFP:JDE:bj /nif encl.

cc: DB-1 NRC Resident Inspector-

-Pete'Wohld, NRC Region III m

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