ML20129J241

Responds to NRC Re Violations Noted in Insp Rept 50-346/85-08.Violation Denied.Trend Analysis Not Explicitly Required by ASME Code

ML20129J241
Person / Time
Site:	Davis Besse
Issue date:	05/17/1985
From:	Crouse R TOLEDO EDISON CO.
To:	Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20129J239	List: IR 05000346/1985008 ML20129J241
References
1-526, NUDOCS 8507220390
Download: ML20129J241 (3)

Text

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Docket No. 50-346 R)LEDO License No. NPF-3 EEE)lEiC)PJ Serial No. 1-526 RICHARO P. CROUSE Vce Presded May 17, 1985 %13, Mr. C. E. Norelius, Director Division of Reactor Projects United States Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Norelius:

Toledo Edison acknowledges receipt of your April 17, 1985 letter (Log No.

1-1152), and enclosures, Notice of Violation, and Inspection Report No.

50-346/85008 (DRS).

Toledo Edison believes that we have not been contrary to the requirements of Section XI of the ASME Code as stated in the Notice of Violation, in that Toledo Edison " failed to trend and evaluate leak rate data". Trend analysis is not explicitly required by ASME Code.

Following an examination of the item of concern, Toledo Edison herein offers information regarding this item.

1. Violation: Davis-Besse Technical Specification 4.0.5 requires that an inservice testing program for pumps and valves be established and conducted per the require-ments of the appropriate edition of Section XI of the ASME Code. ASME Code subsections IWV-3426 and 3427 require that leakage rate measurements for Category A valves be compared with previous measure-ments and specific limits and that valves exhibiting specified leak rate increases or exceeding stated limits be tested at an increased frequency or under-go corrective action, respectively.

Contrary to the above, the licensee failed to trend and evaluate valve leak rate data per the require-ments of Section XI.

This is a Severity Level V violation (Supplement 1).

(85008-02) 8507220390 850715 MAy 2 01986 l PDR ADOCK 05000346 l G p99 l

THE TOLEDO EDISON CCMPANY ED: SON PLAZA 300 MAD: SON AVENUE TOLEDO, OHIO 43652 l l

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D:ckst No. 50-3'46 License-No. NPF-3 Serial No. 1-526 May 17, 1985.

Page 2 Response: (1) . Corrective action taken and results achieved.

Item II.B.I.G, Category A Valve Leak Check Require-ments for Containment Isolation Valves (CIV's), in the Inservice Test Program Safety Evaluation Report (SER) (Log 1521), dated May 18, 1984, states, "The licensee shall comply with Paragraph IWV-3426, Analy-sis of Leakage Rates, and IWV-3427, Corrective Action, unless relief is requested and granted." This SER item also gave.these va3ves Category A status for the l first time and concludc6 that Appendix J Type C testing meets the' intent of IWV-3420 through 3425.

ASME Code Subsection. IWV-3426, states, " Leakage rate measurements shall be compared with previous measure-ments and with the permissible leakage rates specified by the plant owner for a specific valve." Additionally, IWV-3427 states, "If tests show a leakage rate increasing with time for valves six inches nominal pipe size or larger, and a projection based on three or more tests indicates that the leakage rate of the next scheduled test will exceed the maximum permissible leakage rate by greater than 10%, the valve shall be. replaced or repaired."

Local Leak Rate testing per Surveillance Test ST 5061.02, Containment Vessel Local Leak Rate Test, 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.

Toledo Edison has, in the past, as_a good engineering practice, compared the Surveillance Test ST 5061.02 leak rate data against Bechtel guidelines provided in a April 2, 1975 letter. The Bechtel guidelines pro-vide a guide for what should be expected (reasonable leakage rate) and a maximum leakage rate for identi-fying those penetrations which are becoming problem areas. In most cases, if a value or penetration leak rate exceed the maximum leakage rate, corrective action was taken.

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.Dockst No. 50-346 License No. NPF-3 Serial No. 1-526 RMay 17, 1985 Page 3 A comparison of penetration leakage rates following post maintenance is required per Surveillance Test ST 5061.02. This compares _ previous leakage rates to post maintenance leakage rates for acceptability.

(2) Corrective action to be taken to avoid further non-compliance.

Toledo Edison will revise Surveillance Test ST 5061.02 to clarify the requirement to compare leak rate mea-surements with previous measurement and with the per-missible leakage rates.

Additionally, the corrective action guidelines speci-fied in ASME Code. Subsection IWV-3427 will be incor-porated in-Surveillance Test ST 5061.02.

(3) Date when full compliance will be achieved.

Full compliance will be achieved prior to _the next .

refueling outage Local Leak Rate Testing.

Very truly yours, RPC:ECC:SGW:nif cc: DB-1 NRC Resident Inspector.

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