ML20151G612

Notifies of Plans to Use Instrumented Insp Techniques for Applications Listed,Including Implementation Over Next 10 Yrs for Inservice Insp Pressure Test Program & Taking Credit for Inservice Valve Testing

ML20151G612
Person / Time
Site:	Davis Besse
Issue date:	04/11/1988
From:	Shelton D TOLEDO EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML18053A709	List: ML20151G612
References
1486, TAC-69084, NUDOCS 8804200069
Download: ML20151G612 (8)

Text

. _ _ _ _ _ _ _

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% sus EDISON

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DONAU) C. SHELTON Docket No. 50-346 y", @ g *"

License No. NPF-3 Serial No. 1486 April 11, 1988 United States Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555 Subj ect: Notification of Plans to Use Instrumented Inspection Techniques at Davis-Becse Nuclear Power Station Unit No. 1 Gentlemen:

The No: lear Regulatory Commission (NRC) has previously reviewed and approved use of the Instrumented Inspection Techniques (IIT) at the Davis-Besse Nuclear Power Station (DBNPS) Unit No. 1. Consistent with use of the IIT, this information letter is provided to notify the NRC of Toledo Edison's (TED) plans to use IIT at the DBNPS, in the following applications:

1. Implementation over the next ten years, utilizing the system concept (versus component specific) approach, in the Inservice Inspection (ISI) pressure test program and taking credit for the Inservice Testing (IST) program valve testing.

2. Main Steam System (including steam generators) pressure testing during Mode 5 or subsequent plant heatup.

3. Repairs and replacements testing using IIT, in lieu of Section XI IWA-5000, for IWA-4400 welded repairs on:

• Service Water

• Main Steam System

• Decay Heat

• Auxiliary Feedwater Steam

• Auxiliary Feedwater Water

• Hign Pressure Injection

4. Ten minute hold time in lieu of 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> hold time on insulated lines for the following systems:

• Steam Generator

• Main Steam System 411

• Service Water 89042j@h[$$o00' 6 pf.h

• Decay Heat I a O

• Auxiliary Feedwater Stea.a i\

• Auxiliary Feedwater Water THE TOLEDO EDfSON COMPANY EOtSON PLAZA 300 MAOfSON AVENUE TOLEDO, OHIO 43652

l Docket No. 50-346 '

License No. NPF-3 Serial No. 1486 Page 2 l

5. Testing of pump suction piping up to the first discharge isolation valve at normal operating pressures. '

Each of the above applications was previously discussed with NRC staff members for IIT application at different sites including DBNPS. These meetings were held on February 4, 1986 (Reference 7), September 30, 1987 (Reference 6), November 5, 1987 (Reference 5), and January 6, 1988 (Reference 4), and the respective meeting minutes are included in Attachment 2. Previous NRC approval for use of these listed items in similar systems was provided in an h3C letter dated February 29, 1988 (Reference 1) for application at Beaver Valley Units 1 and 2. (References are contained in Attachment 2).

Discussion and methodology regarding each of the above topics are presented in Attachment 1.

If you have any questions, please contact Mr. R. W. Schrauder, Nuclear Licensing Manager, at (419) 249-2366.

Very truly yours, l

RMC:JDE:bam Attachment cc: DB-1 NRC Resident Inspector, w/a A. B. Davis, Regional Administrator (2 copies), w/a A. W. DeAgazio, NRC/NRR, DB-1 Project Manager, w/a G. Johnson, NRC/NRR, w/a

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Docket No. 50-346 License No. NPF-3 l . Serial No. 1486 L Attachment 1 L Page 1 ATTACHMENT 1 - DISCUSSION AND METHODOLOGY As stated in Page V of the NRC Safety Evaluation Report, dated November 5, 1985, for acceptance. of. Topical Report HAFA 135 (P):

"The information andidata' contained in'the topical. report were pre-sented to demonstrate that the Instrumented Inspection Technique is c

capable of detecting and locating external system leakage, intersystem valve leakage, reducing personnel exposure to radiation, detecting small leaks, eliminating overpressurization of lower pressure rated piping and components, and is therefore a suitable alternative to Section XI requirements for hydrostatic tests."

Subsequent to the issuance of the Topical Report.HAFA 135 (P-A) IIT has been performed in over 200 tests in the industry. IIT has demonstrated at the DBNPS and other nuclear power plants the capability of detecting intersystem leakage and external leakages that were not found by conventional pressure testing on systems and components in the Safety Injection System, Auxiliary Feedwater System, Component Cooling Water System, Safety Injection Tanks, Residual Heat Removal System, etc.

Drawings, diagrams, or sketches for application of IIT on specific systems have been included in Attachment 3. Test boundaries have been colored yellow. The following symbols have also been used:

() Valve Replacement

((] New valve added

/i Spool thru O Internals removed

1. IIT IMPLEMENTATION OVER THE NEXT 10-YEAR INTERVAL It is TED's intention to implement the IIT methodology for DBNPS on systems and components that are impractical to test using conven-tional ASME Section XI hydrostatic testing. The IIT testing will be performed on an ongoing basis with a percentage of the tests being completed each refueling outage.

Utilizing the IIT methodology will avoid repeating the massive testing efforts that are required to complete the first 10 year Inservice Inspection (ISI) interval pressure tests.

It is TED's intention to take credit for performing pressure, functional, and valve testing when the IIT technology is utilized.

This schedule of testing is consistent with the information of

! Topical Report RAFA 135 (P-A) and several informational meetings previously held with NRC staff.

Docket No. 50-346 License No. NPF-3 Serial No. 1486 Page 2

2. STEAM GENERATORS During the IIT testing, NerG Enterprises, Inc. Electro Acoustic Ranging System (EARS), or demonstrated equivalent, will be used to monitor the Steam Generators (SG) from the upper to the lower tube sheet (outer shell only) for leaks. The test will not include detection of leaks through the secondary to the primary boundary, i.e., through the steam generator tubes or tube sheet to the Reactor Coolant System.

Acoustic Emission (A.E.) sensors will be bonded to the outer shell of the SG similar to that shown in the attached sketch (Attachment 3, Figure 1). The NerG Enterprises, Inc. EARS, or demonstrated equivalent, will be used to monitor locational events and other A.E.

parameters indicative of leakage. Preamplifiers will be located consistent with accepted sensor / preamplifier spacing, similar to that previously utilized at Beaver Valley Unit No. 1.

The test will be performed in either Mode 5 or during plant heatup in Modes 3 and-4 during the fifth or sixth refueling outage (5RF0 or 6RF0, respectively). The subsystem, if tested during Mode 5, will be filled solid with water to obtain pressure and insure that temperature is greater than 130 F (for control of fracture toughness). Necessary spring hangers will be pinned and will be inspected before and after the test. A visual inspection will be conducted following each 10-minute hold time at both 600 psig and 935 psig. During the hold periods, the SG and connecting piping within 20 feet will be maintained in an acoustically quiet state to permit optimum detection of leaks.

3. REPAIRS AND REPLACEMENT

a. Service Water System (Attachment 3, Figures 2, 3, and 4)

Valve Numbers SW 79 SW 134 SW 382 SW 117 SW 14 SW 372 SW 83 SW 130 SW 15 SW 82 SW 329 SW 57 SW 6391 SW 218 SW 91 SW 78 SW 335 SW 44 SW 109 SW 217 SW 43 SW 99 The above valves are either being replaced, having internals removed or being physically removed and spooled through. During an informal meeting with NRC staff on September 30, 1987, modifications to this system were discussed, including the use of the IIT methodology for repairs and replacements. The justification for using IIT in lieu of conventional hydrostatic testing is:

(1) system relief valves would have to be blanked or gagged, (2) check valves would have to be hydrostatically tested in the reverse direction, and

Docket % . 50-346 l License No. NPF-3 Serial No. 1486 Page 3 (3) the ability of IIT to measure intersystem leakage.

The attached P&ID's (Attachment 3, Figures 2, 3 and 4) identify by symbol the valves being replaced, having internals removed, or being spooled through. The testing of the Service Water (SW) system will be performed in Mode 5 with a 10 minute holdtime at operating pressure for VT-2 examination. It is presently planned that modifications to this system will be tested by IIT during the SRF0.

It should also be noted that any repair or modification to this system will also be inspected by the Non-Destructive Examination (e.g., PT, MT, VT, etc.) as required by applicable tode requirements.

b. Main Steam System (Valve Nos. MS 100A, 101A, MS 375, MS 394)

(Attachment 3, Figures 5 and 6)

The IIT methodology for the Main Steam System was discussed with NRC staff members on September 30, 1987 (Reference 6). This testing will utilize the IIT methodology that was employed and approved by NRC letter dated February 29, 1988 (Reference 1).

The testing will be performed during the SRF0 during Mode 4 through Mode 3. The system will be held at normal operating pressure during Mode 3 to perform the VT-2 examination.

It should be noted that any applicable valve repair or replace-ment will also be inspected by the Non-Destructive Examination per applicable Code requirements.

Justification for the use of IIT in lieu of conventional hydro-static testing was identified in Topical Report HAFA 135 (P-A) under the discussion regarding main steam system testing.

The attached color coded P&ID's identify which valves are being replaced (Attachment 3, Figures 6 and 9).

c. Decay Heat Removal (Valves Nos. DH 13A & B, 14A & B) (Figures 7 and 8)

The IIT methodology for this system was discussed with NRC staff members on September 30, 1987 (Reference 6). The testing of this system will be performed in Mode 5 with a 10 minute hold time at normal operating pressure to perform the VT-2 examination.

Justification for IIT methodology in lieu of conventional ASME Section XI hydrostatic testing is:

Docket No. 50-346 License No. NPF-3 Serial No. 1486 Page 4 (1) IIT eliminates gagging relief valves, and (2) IIT methodology has the ability to measure and identify intersystem leakage.

It should be noted that any repairs and replacements will also be inspected by the Non-Destructive Examination as required by applicable Code requirements. Figures 7 and 8 are included in Attachment 3 for ease of review,

d. Auxiliary Feedwater Pump Turbine Steam Supply (Valve Nos.

MS5889A & B) (Attachment 3, Figure 10)

This submittal satisfies the request of Mr. G. Johnson NRC/NRR (Reference 7, third paragraph) for descriptive information regarding the the use of IIT for the Auxiliary Feedwater Pump Turbine Steam Supply lines. The test will utilize the IIT methodology that was employed and approved by NRC letter dated Februa ry 29, 1988 (Reference 1). The testing will be performed during the SRF0 in Mode 4 thru Mode 3, with a 10 minute holdtime at normal operating pressure in Mode 3 to perform the VT-2 examination. This test will be performed in conjunction with the Main Steam System testing. It should be noted that any applicable valve repair or replacement will also be inspected by the Non-Destructive Examination per applicable Code requirements.

The justification for using IIT in lieu of conventional hydrostatic testing is that the IIT methodology eliminates pinning the check valves or removing the valve internals. Attached for case of review is a color coded P&ID diagram (Attachment 3, Figure 9).

e. Auxiliary Feedwater Pump Discharge Containment Isolation (Valve Nos. AF 599, AF 608)

The IIT methodology for this system was discussed with NRC staff members on September 30,1987 (Reference 6) and November 5,1987 (Reference 5). The test will utilize the IIT methodology that was employed and approved by NRC letter dated February 29, 1988 (Reference 1). The testing will be pertormed during either the SRF0 or 6RF0 in conjunction with the SG test. Any applicable valve repair or replacement will also be inspected by the Non-Destructive Examination per applicable Code requirements.

Docket No. 50-346 License No. NPF-3 Serial No. 1486 Page 5 Justification for the use of IIT in lieu of conventional hydrostatic testing is identified in the Topical Report HAFA 135 (P-A) under main steam line testing. Attached is a color coded P&ID identifying the valves that are to be replaced (Attachment 3, Figure 10).

4. TEN MINUTE HOLDING TIME As discussed with NRC staff members during meetings on February 4, 1986 (Reference 7), September 30, 1987 (Reference 6), November 5, 1987 (Reference 5) and January 6,1988 (Reference 4), the two hour holding time requirements werc determined not to be warranted when using the IIT methodology since data is being taken from test time zero to normal operating pressure, which in most cases far exceeds the two hour holding time. IIT has also demonstrated the capability to detect leakage at pressures far below normal operating pressure, as previously discussed with NRR staff members. Based upon the above, the 10 minute holding time at normal operating pressure will be applied on the systems previously listed in this attachment. A VT-2 walkdown will be performed af ter the 10 minute hold time.

Docket No. 50-346 License No. NPF-3 Serial No. 1486 Attachment 2 Page 1 REFERENCES Reference 1 P. S. Tam, NRC Beaver Valley Project Manager, to J. D. Sieber, Vice President, Duquesne Light Company, dated February 29, 1988 (TAC #61349).

Reference 2 Log No. 1861, J. F. Stolz, Chief, NRC/NRR Operating Reactors Branch #4, to J. Williams, Jr., Senior Vice President -

Nuclear, Toledo Edison Company, dated November 13, 1985.

Reference 3 Serial No. 1199, J. Williams, Jr., Senior Vice President -

Nuclear, Toledo Edison Company, to J. T. Stolz, Chief, NRC/NRR Operating Reactors Branch #4, datad October 18, 1985.

Reference 4 Meeting minutes of January 6, 1987, NRC and HAFA (HAFA #H11-88-2000).

Reference 5 Meeting minutes of November 5, 1987, NRC and HAFA (HAFA #H11-87-1255).

Reference 6 Meeting minutes of September 30, 1987, NRC/TVA/HAFA/TED (HAFA #H11-87-1227).

Reference 7 Meeting minutes of February 4, 1986, NRC/HAFA (HAFA #H11-86-1134-T).

l

F Docket No. 50-346 License No. NPF-3 Serial No. 1486 Attachment 2 Page 2

,# 'o,, UNITED STATES e o NUCLEAR REGULATORY COMMISSION Reference No. I g E W ASHINGTON, D. C. 20555

%,*..I.* / February 29,19M(

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Docket Nos. 50-334 M 50-412 Mr. J. D. Sieber, Vice President sA94 9 pS s

L Duouesne Light Company D g6 Nuclear Operations y f Post Office Box 4 Shippingport, Pennsylvania 15077

SUBJECT:

BEAVER VALLEY UNITS 1 AND 2 - INSTRUMENTED INSPECTION TECHNIQUE (IIT) (TAC NO. 61349)

By letter dated January 15, 1988, you provided to us follow-up documentation on a phone conversation held on January 6,1988, between your contractor, HAFA International ~ and the NRC staff. The purpose of your letter is to notify' us of your intention to use IIT in the following ways:

1. Implementation over the next ten-year interval,

2. Steam generator hydro-testing during Mode 5'and subsequent plant heatup,

3. Repair and replacement testing on feedwater elbow, safety injection and seal injection filter valves,' and

4. Ten-minute holding time in lieu of two-hour on partially insulated lines on the safety injection and component cooling water systems.

Our approval for your use of IIT at Beaver Valley Units 1 and 2 were documented in letters dated May 15, 1986 and October 2, 1987, respectively.

We have reviewed your January 15, 1988 letter and found your application of IIT acceptable. This review was performed by Mr. G. Johnson.

Sincerely,

^

l P ter S. Tam, Project Manager

' Project Directorate I-4 Division of Reactor Projects I/II cc: See next page

$5 $ 3&c3 l 9$ lf '

Docket No. 50-346 License No. NPF-3 Serial No. 1486 Attachment 2 Page 3 Reference No. 2 o

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Docket No. 50-346 c. t can t.t L. Stewart

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Mr. Joe Williams, Jr.

Vice President, Nuclear WOV 191985

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% ae.es Toledo Edison Company J .Ewid Edison Plaza - Stop 712 300 Madison Avenue MM E .c.ak Toledo, Ohio 43652

SUBJECT:

REQUEST FOR APPROVAL TO USE AN ALTERNATIVE PRESSURE TESTING METHOD -

DAVIS-BESSE NUCLEAR POWER STATION.

By letter dated October 18,1985 (Serial No.1199), Toledo Edison company requested approval to use an alternative inspection method to meet the requirements of Section XI of the ASME Code for inservice pressure tests at Davis-Besse. The alternative testing method, Instrumented Inspection Technique, is described in a topical report submitted to the NRC by HAFA International Incorporated by letter dated April 4,1985 to demonstrate that the proposed alternative would provide an acceptable level of quality and safety as required by 10 CFR 50.55a(a)(3).

We have reviewed and evaluated the proposed alternative testing method as discussed in the topical report. We have detemined that the alternative testing method provides added assurance of system and component structural integrity and leak tightness when compared to conventional pressure testing and is therefore an acceptable alternative. We have also deteminea that the small leak detection and location capabilities of the alternative method make it applicable for intersystem leakage detection, and that the four-hour hold time requirement prior to visual inspection of the systems may be reduced to two hours. We therefore approve its use as an alternative testing method as requested in your letter, incerely, ,

J M 4 UL Joh$ F. Stolz, Chief.

Spdrating Reactors Branch #4 Division of Licensing l cc: See next p ne N M thicNr f.:, Cegr lead Les twmt.

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