ML20094M476
| ML20094M476 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 03/27/1992 |
| From: | Shelton D CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1-979, NUDOCS 9204010004 | |
| Download: ML20094M476 (4) | |
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- 2. CENTERIOR ENERGY Donald C. Sheltori 310 Mdson Avenue Vce Presdent Hudent Toleda. OH 43%2 0001 Dwis Bene (419)249 2300 Docl< e t tiumbet 50-346 License ilumbet flPF-3 SetJn1 tiumber 1 979 f4 arch 27, 1992 Unite l States fluelear Regulator y Connnisalon Document coattol Desk Washingt.on, DC 20555 Subjecti Response to Initial Systematic Assessmer.t of Licensee Portormance (SALP) 9 Report (IR 91001) c 4
centlement Toledo Edison Cornpany (TE) han rev iewed t he initial SALP 9 Report (Inspr etion Peport flo. 50-346/91001) for the Davin-Besse fluclear Powe; St nt ion. :overing the period July 1, 1990 through flovember 30, 1991.
The SALP tr anr' nit t al letter (Log flumber 1-2601), dated Fe'stuary 5, 1992, stated that TE may provide written conunents to thee llRC within 30 days af ter the t! arch 3.
1992. SALT 9 meetlun,.
At tached are YE's consnents concetning the SALP 9 Report.
If you should have any questions regarding this mat ter, please contact lir R. W. Schrauder, tlanager - fluclear Licensing, at (419) 249-2366.
Very t ruly yot; rs,
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A. B. Davis, Regional Administrator, llRC Region III J. B. Hopkins. IIRC/flRR DB-1 Senior Project flanager W. Levi 9, DB-1 IIRC Senior Resident Inspector Ut ility tudlclegical Saf ety Board
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pocket flumber 50-346 License 11 umber flPF-3 Setial fiumber 1-979 1
Pa k,e 1 RESP 011SE TO IfllTIAL SALP Q REPORT i
1.
AS!!E Code i
On Page 12. in the Engineering / Technical Support (E/TS) analysis section (paragraph 2), the Init.ial SALp repot t statess "The licenoce's application of the American Society of Hechanical Engineer's (ASME) Code at times lacked thoroughness, most notably in an application dealing with steam generator tube plugging.
In this case. an ASHE Code relief focused on an automatic welding pror.ss without sufflcient recognition of the unique plug and weld Jesign. Hisinterpretations of the AEME Code also were noted in the submittal of the licensee's second 10-year inservice testing program for pumps and valves.*
..s presented, this statement in the SALp Report incorrectly creates the perception of a y,eneral weakness-in the understanding and thorough application of ASHE Code requirements.
The fact.s surrounding the examples provided in the SALp Report do not support the conclusion reached.
In tact.. activities accomplished during the SALp.9 period deraonstrated a general strength in both understanding and application of ASME code requiremerit n.
An example of thorough /$5HE Code application duriag the SALP 9_ period
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involved a proposed alternative to Section XI of the ASH 6 Code.
It involved inspections of the outside diameter weld surfaces of the core flood anJ seactor vessel nortles.
Th.is effort by TL avolded at least 60 nem anticipated from using the inspection techniques specified In the ASME Code.
Toledo Edison's commitment to proper Interpretad on and application of the Abi1E Code was exemplified by the. formation of a Dav!s-Besse ASHE~ Code Committee.
This committee has been successful in reviewing and advising.
l TE personnel / departments on ASME Code queries.
In additlop. TE has been active in obtaining and maintaining the flational Board Inspection Nucient Repair (11R). Valve Repair (VR). and Repair (R) Stamps for added Code-compliance.
l A.
. Steam Generator Tube Plug Toledo Edison contracted ABB/ Combustion Engineering (CE) to perform steam generator inspections and steam generator tube plug 1
installations-for the seventh refueling outage.
In one steam generator tube location where a backup plug was required, a welded plug was specified because of. insufficient clearanco'for a mechanical plug.
During its review of CE's methodology for-installatlon of the i_
backup plug. TE identifled that the automatic welding process for..
steam generator tube plugging in not sanctioned by-Gection XI.of the.
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1986 edition of the-ASHE Code. Although tne automatie weldlng process is sanctioned by the 1989 edition' of. the ASME Code, the 11RC has not yet endorsed that edition.-
Docket flumber 50-346 License llumber llPF-3 Serial flumber 1-919 Page 2 Toledo Edlwon'c attrition to detail and Code knowledge was manifested in TE's request fut relief item AS!!E Code Section XI to permit N
machine welding of steam genetator plugs in a letter dated Septembet 3 1991 (Settal 1978).
Prior to submittal of the tv11ef requent, as part of its independent design verification process. TE tesleved the acceptability of the plug design specification.
In addition. CE was lequested to submit a letter of justificalion and a stress report for the proposed weld design and plug maserial 11100 02.
Based on reviews of the AS!!E Code, the information supplied by CE. and the sucessasiul performance ut the 1:1C0 82 welded plug in other plants. TE concluded that tbo weld design and olug material were acceptable and in compilance with the 1986 edition of Section XI of the AS!!E Code.
Since the only-depattute itom ASitE Code requitementa was in the area of the automatic welding process, the relief request (Serial 1978) centered on the welding ptotenst other t.echnical Information was not intended to be included.
tiot withstanding the above, the llRC's review of the tellet request focused on the plug material and weld design. As a tesult, t.he ilRC quest loned CE's material select ion and weld design of the backup plug. Follov.up information and test reports were cent to the flRC to i
support the use_ of IllCO 02 with-the proposed weld design in steam -
generator tube plugging applications.
1he flRC acc eptad the automatic welding process, proposed plug material, and weld design in its Safety Evaluation Report (SER) dated October 31, 1992 (Log 3614),
Although the plug material and weld design lunuen were resolved, the llRC requested infotitation be provided by the end of the eighth refueling outage on long tetm corrosion of IllCO 82 in steam generator tu')e plugging appilcations.
In conclusion, characterizing TE as having a lack of thoroughness based on the steam generator tube plugging issue 10 inuppropriate.
The SALP 0 ilual report should be rev.ised to accurately chatacterize i
the issue.
B.
10 Year Inservice Testin d 1ST) Pt;ogram Toledo Edison submitted the second 10 year IST program on March.22, 1990.
Toledo Edison identitled arer,o where compliance with ASilE Code requirements was considered impractical or inurdensome.
In these-cases. relief was requested.
The issue does not involve _
misinterpretation or omission of ASHE Code requirements.-It _ _ involves the adequacy of justification for Code relief.
Thin is different than raisinterpretation or emission. The final SALP 9 report should
'be revised to include this clarification.
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Socket llumber 50 346 Licen Je llumber 11P!'-3 Seri51 flumber,1 979 At t achment. 1 l' age 3 2.
Egineer ing St af f Knowlydge DeficiencJe,s on Page 13 In the E/TS analysin sect ion (paragiaj'h 1), the initial fiALP repott staten:
'Although some knowledge deficiencies wete noted in the enginee:Ing department, the ovetall ef f ectiveneue of training in the engineering niea...was good."
Based on utatemente made by the llRC at the !sALl' 9 meeting at Davis-Besse -
on liarch 3. 199?. it in TE's understanding that the final SALP 9 report will be revised to remove the teference to ' knowledge deficiencies'.
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