IR 05000346/1985008

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-346/85-08. Violation Re Trending of Valve Leak Rates Occurred as Stated

ML20129J235
Person / Time
Site:	Davis Besse
Issue date:	07/15/1985
From:	Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Crouse R TOLEDO EDISON CO.
Shared Package
ML20129J239	List: IR 05000346/1985008 ML20129J241
References
NUDOCS 8507220389
Download: ML20129J235 (2)

Text

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JUL 15 Gd5 Docket No. 50-346 Toledo Edison Company ATTN: Mr. Richard P. Crouse Vice President Nuclear Edison Plaza 300 Madison Avenue Toledo, OH 43652 Gentlemen:

Thank you for your letter dated May 17, 1985, informing us of the steps you have taken to correct the violation which we brought to your attention in Inspection Report No. 50-346/85008(DRS), forwarded by our letter dated April 17, 198 With regard to your response, we reviewed the Safety Evaluation Report dated May 18, 1984, item II.B.1.g and the requirements delineated in the 1977 Edition of Section XI of the American Society of Mechanical Engineers' Boiler and Pressure Vessel Code, Subsections IWV-3426 and IWV-3427. While trending of valve leak rates is not explicitly required by the Code, it would be impossible to determine whether leak rates projected " based on three or more tests" would indicate "that the leakage rate of the next scheduled test" would exceed the acceptance criteri In your response, you stated that " local leak testing was conducted during the 1984 Refueling Outage and provided the first leakage rate measurements to be compared under the new requirement to comply with the ASME Code Subsection IWV-3426 and 3427". 10 CFR 50.55a(g). states that inservice testing shall comply with the appropriate edition of the ASME Code, which in this case is the 1977 Edition including Addenda through Winter 1978, unless specific relief is granted by the Commission. Although the Safety Evaluation Report was issued in May, 1984, you committed to the 1977 Code in your revised submittal dated May 15, 1980. The requirements of IWV-3426 and IWV3427 are quite clear and evaluations of the three tests con-ducted prior to the 1984 test must be analyzed per the Code criteria. While the staff agrees that the comparison of leak test data obtained via Surveillance Test ST 5061.02 against the Bechtel guidelines is a good engineering practice, such comparisons are required per Subsection IWV-3426. The requirements of IWV-3426 and IWV-3427 apply to all valves requiring leak rate measurements, including pressure isolation valves. Revisions to procedures regarding the evaluation and trending for valves requiring leak testing in addition to ST 5061.02, must be initiate It was noted during the inspection that no method nor provision for the evaluation required by the Code was planned to be implemente .

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Toledo Edison Company 2 JUL 151985 Therefore, we do not agree with your position that ycu have not been contrary to the requirements of Section XI of the ASME Code. Your actions in this regard will be reviewed in subsequent inspection Your cooperation with us is appreciate

Sincerely, n

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,R. pessard, Director Division of Reactor Safety cc w/ltr dtd 5/17/85:

T. D. Murray, Station Superintendent DMB/ Document Control Desk (RIDS)

Resident Inspector, RIII Harold W. Kohn, Ohio EPA James W. Harris, State of Ohio Robert H. Quillin, Ohio Department of Health

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