ML20211P578

Provides Description of Current Snubber Insp & Svc Life Monitoring Process & Plant Plans to Revise Current Life Monitoring Process to Reflect Recommendations of Nonmandatory App F Svc Life Monitoring of ASME Oma Code

ML20211P578
Person / Time
Site:	Davis Besse
Issue date:	10/14/1997
From:	Jeffery Wood CENTERIOR ENERGY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
2491, GL-91-04, GL-91-4, TAC-M96602, NUDOCS 9710210027
Download: ML20211P578 (4)

Text

,. . .

CENTERDOR ,

ENERGY.

5501 N State Route 2 419-249-2300 Johri K. Wood oak Haft)or. OH 43449 FAX; 419-3218337 Vce Presders - Nuclear Davts-Besse Docket Number 50-346 License Number NrF-3 Serial Number 2491 October 14, 1997 United States Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555-0001

Subject:

NRC Review of 24-Month License Amendment Request Number 95-0019 Regarding Snubber Inspection and Service Life Monitoring at the Davis-Besse Nuclear Power Station (TAC No. M96602)

Ladies and Gentlemen:

Toledo Edisor (TE) submitted License Amendment Request (LAR) Number 95-0019," Proposed Modification to the Davis-Besse Nuclear Power Station (DBNPS) Unit i Facility Operating License NPF-3 Appendix A, Technical Specifications for Conversion to a 24-Month Fuel Cycle,"

on September 17,1996, (TE Letter Serial Number 2383) to the NRC. Enclosure 4 of LAR 95-0019 provided a summary of the Licensing Basis, Surveillance Data, and Maintenance Record .,

Reviews for Technical Specification (TS) 3/4.7.7, Plant Systems - Snubbers, Surveillance Requirement (SR) 4.7.7.2.b.

License Amendment Request 95-0019 concluded, based on the above reviews completed in accordance with the recommendations of Generic Letter 91-04," Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," that there is no adverse effect on plant safety due to increasing the snubber surveillance test intervals from 18 to 24 months for TS SR 4.7.7.2.1,. However, during the course of review, the NRC staff requested, via a telephone call on July 17,1997, additional information regarding TS snubber inspection

. and service The monitoring at the DBNPS.

A description of the current snubber inspection and service life monitoring process, and the

, DBNPS's plans to revise the current service life monitoring process to reflect the recommenda-tions of nonmandatory Appendix F (Dynamic Restraints (Snubbers) Service Life Monitoring Methods) of the ASME OMa Code - 1996 Addenda,is provided in the enclosure to this letter, r ,, i ooj v.

9710210027 971014 "

PDR P

ADOCK 05000346 PDR-gllggl jj,

. ,, gg

Docket Number 50-346L

. License Number NPF-3

Serial Number 2491 -

.- ! Englosure Page 2 --

_ Should you have any questions or require additional information, please contact -

- Mr. James L. Frects, Manager - Regulatory Affairs, at (419) 321-8466.

._Very truly yours, 5

F K/laj enclosure -

cc

- A. B. Beach, Regional Administrator, NRC Region III

- A. G. Hansen,= DB-1 NRC/NRR Project Manager J. R. Williams, Chief of Staff, Ohio Emergency Management Agency,

- State of Ohio (NRC Liaison)-

S. Stasek, DB-1 NRC Senior Resident Inspector Utility Radiological Safety Board

"^

_m__-m__w _.._ _ _ __.: a__ __ .__ __

" Docket Number 50-346 License Number NPF-3 Serial Number 2491

. Enclosure Page1 SNUBBER INSPECTION AND SERVICE LIFE MONITORING AT THE DAVIS-BESSE NUCLEAR POWER STATION Snubber Insnections:

The snubber inspection process at the Davis-Besse Nuclear Power Station (DBNPS) is mandated by the requirements of the Operating License, Appendix A, Technical Specifications (TS).

Technical Specification 3.7.7 requires that all safety-related snubbers shall be operable in plant operational Modes 1,2,3, ard 4, and in Modes 5 and 6 for those plant systems required to be operable during Modes 5 and 6.

The TS Surveillance Requirements (SR) require that these snubbers be demonstrated operable pursuant to the requirements of TS 4.0.5 (inspection and testing of ASME Code components) and by the performance of visual inspections at the intervals specified by SR 4.7.7.1. Also, a representative sample of each group of snubbers in use in the plant shall be functionally tested in accordance with SR 4.7.7.2.b and 4.7.7.2.c.

The Surveillance Requirements are implemented by DBNPS Procedure DB-MM-03006,

" Inspection of Tech Spec Hydraulic Snubbers." This procedure provides the method by which the DBNPS snubbers are inspected and as-found functionally tested to ensure they remain capable of performing their intended function. Data collection and archiving are also required and controlled by this procedure.

The snubbers chosen for examination are selected through the use of a Snubber Testing / Rebuild List. This list is maintained under the sapervision of the Superintendent of Mechanical Maintenance. It is updated prior to each inspection interval for visual inspections and prior to each refueling outage for functional testing and rebuilding. This list is comprised of both Technical Specification-required snubbers and also Seismic II/I snubbers.

Data sheets are used during the inspection to record visual inspection criteria and functional testing. A " remarks" section provides a means to record any discrepancies or deviation from requirements. Snubbers found with deficiencies are evaluated by the Maintenance Engineer assigned responsibility for the snubber inspection and service life monitoring process.

Deficiencies are noted on a test deficiencies list and, as appropriate, entered into the DBNPS Potential Condition Adverse to Quality Reporting (PCAQR) program. This program ensures that an evaluation of the cause of the entered-deficiency is performed and that appropriate corrective action is completed.

All data acquired during the performance of the surveillance testing becomes part of the s

permanent plant records of the Nuclear Records Management System.

l 1

. .1 :e 7* ocket Number 50-346 -

License Number NPF-3 Seria! Number 2491 -

.z , Enclosure Page 2 -

Service Life Monitorine

Service life monitoring is encompassed by the review of deficiencies and by the PCAQR process.

The Maintenance Engineer assigned to plant snubbers, has developed and maintains a database that is used to predict and evaluate snubber service life in conjunction with the Maintenance Engineering review and PCAQR process, in order to optimize snubber availability during plant -

- operation. The database hsts information on each plant' snubber such as identification number,-

snubber type, snubber group, snubber size, : cation, whether accessible or inaccessible, special conditions (such as pertinent environmental conditions and the radiation environment), a listing of the maintenance work orders (which detail the history of each plant snubber), and the ambient operating temperature.

- The service life monitoring process is being formalized as a program by the DBNPS staff.

Although not mandatory, the DBNPS staff plans to base this program on the recommendations of i Appendix F (Dynamic Restraints (Snubbers) Service Life Monitoring Methods) of the ASME - -,

- OMa Code - 1996 Addenda. In addition to the service life monitoring already performed by the Maintenance Engineering review, and the PCAQR process, it is planned that the program will

- specifically incorporate trending of selected parameters in order to further predict and reevaluate snubber service life. The program will be based on knowledge of the operating environment,'

_ snubber design limits, and service records. This ' service life monitoring process will be formalized as a program by March 14,1998.

u

.__.______m.m .-_. .._i-