ML20216D519
| ML20216D519 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/07/1998 |
| From: | Jeffery Wood CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 2529, NUDOCS 9804150332 | |
| Download: ML20216D519 (6) | |
Text
I E*.
--LF" Davss Besse Nucica' Power Station j
g gg 550I North State Route 2 m
Oak Harbor, Ohio 43449-9760 John K.n%od 419 249 2300 Vice President - Nuclear Fat 419-321-8337 Docket Number 50-346 i
License Number NPF-3 Serial Number 2529 April 7, 1998 United States Nuclear Regulatory Commission 3
Document Control Desk Washington, D.C. 20555-0001
Subject:
Response to Request for Additional Information Pertaining to Relief Requests from Certain ASME Code Requirements for the Davis-Besse Nuclear Power Station Ladies and Gentlemen:
Toledo Edison requested relief from certain requirements of Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code for the Davis-Besse Nuclear Power Station (DBNPS) by letter to the Nuclear Regulatory Commission (NRC) dated December 22,1997, (Serial Number 2506).
On March 16,1998, DBNPS received a request for additional information for Relief Requests RR-E2, RR-E3, RR-E4, RR-E6 and RR-E7 from the NRC Staff. Toledo Edison responded initially to this request for additional information in a March 17,1998, telephone conference call with the NRC Staff. During this phone call, additional questions were raised regarding Relief Request RR-El. Toledo Edison received the Request for Additional Information from the NRC by letter dated March 18,1998,(Log Number 5233). Attached is Toledo Edison's response to the Request for AdditionalInformation.
Should you have any questions or require additional information, please contact Mr. James L.
Freels, Manager - Regulatory Affairs, at (419) 321-8466.
Very truly yours, w
~,,
u CA Ic Attachment cc: A. B. Beach, Regional Administrator, NRC Region III
)
A. G. liansen, NRC/NRR Project Manager S. J. Campbell, NRC Region III, DB-1 Senior Resident Inspector t
aO Utility Radiological Safety Board
['
9004150332 980407 PDR ADOCK 05000346 P
l Docket Number 50-346 License Number NPF-3 l
Serial Nurnber 2529
. Attachment Page1 TOLEDO EDISON RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION PERTAINING TO RELIEF REQUESTS FROM CERTAIN ASME CODE REQUIREMENTS A. Relief Request RR-El, Containment Inspection Seals and Gaskets
- 1. NRC Request:
During the March 17,1998, telephone conversation, the Nuclear Regulatory Commission (NRC) requested information on periodic inspections on main door gaskets such as the Equipment Hatch, Personnel Hatch, and Emergency Escape Hatch.
- 2. Toledo Edison Response:
The Equipment Hatch is removed during maintenance outages, when necessary, and
)
during each refueling outage. Prior to final closure, the hatch gaskets and door sealing face are inspected for damage which could prevent sealing. The Personnel Hatch and Emergency Escape Hatch are included in the Davis-Besse Nuclear Power Station j
(DBNPS) Preventive Maintenance Program. This program requires that the door gaskets 1
be inspected for damage which could prevent scaling and be coated with an approved silicone lubricant to preserve their integrity. These inspections are performed each refueling outage. Prior to establishing containment integrity, the Equipment Hatch, Personnel Hatch, and the Emergency Escape Hatch are tested in accordance with 10 CFR 50 Appendix J to confirm their sealing capability.
B. Relief Request RR-E2, Containment Inspection, NDE Personnel Qualification and Certification
- 1. NRC Request:
"RR-E2: In the basis for relief section, you state that the use of CP-189 will not improve the capability of examination personnel. Inclusion of these standard in the 1992 Edition and later Edition and Addenda of the Code suggests that it is an experience-based improvement over SNT-TC-1 A. Also, it is a consensus (ANSI) standard. Please provide your plans to implement Subarticle IWA-2300 (1992 Edition and Addenda) for qualifying NDE personnel for all the ASME Section XI components, and containment in particular."
- 2. Toledo Edison Response:
The DBNPS Second Ten Year Inservice Inspection Program is written in accordance with the requirements of the 1986 Edition of ASME.Section XI. The DBNPS is presently in the third period of the second ten year inspection interval. This interval expires on I
September 21,2000. At that time, it is Toledo Edison's intent that the DBNPS Inservice
F 1
l l
l Docket Number 50-346 License Number NPF-3 Serial Number 2529 a
1
. Attach nent t
Page 2 Inspection Program will be updated to the Code, including CP-189 or other requirements, i
and 10 CFR 50.55a as required. Until that time, DBNPS will continue to implement the requirements ofIWA-2300 of the 1986 Edition of.ASME Section XI for the ASME Class l
1,2 and 3 components as well as the containment examinations required by IWE.
Subsection IWL is not applicable to the DBNPS.
l Containment examinations are primarily performed using visual examination methods.
Volumetric examinations (minimum wall thickness readings) are required on Containment Surfaces Requiring Augmented Examinations (Examination Category E-C)
)
or areas requiring examination to characterize visual examination indications. Only I
personnel qualified to a minimum Ultrasonic (UT) Level 11 or a limited certification as UT Level 11 for Ultrasonic Thickness (UTT) readings will be used to perform volumetric examinations. These certified personnel are typically the personnel who perform UT examination for flaws in welds of Class 1,2, and 3 components and for flow acclerated corrosion thickness readings. At this time, DBNPS has not identified any areas which require volumetric examinations.
IWA-2300 of the 1992 Edition,1992 Addenda, of ASME Section XI requires that nondestructive examination (NDE) personnel be qualified in accordance with ANSI /ASNT CP-189 as amended by IWA 2300. IWA-2313,"NDE Methods Not Listed
' in ANSI /ASNT CP-189," states " Personnel performing visual examinations or using other NDE methods not addressed in ANSI /ASNT CP-189 shall be qualified and certified to co nparable levels of qualification as defined in ASN!/ASNT CP-189 and the Employer's written practice."
As required by 10 CFR 50.55a and the referenced Code requirements for Class 1,2, and 3 components, the DBNPS written practice is based upon the requirements of ANSI N45.2.6 and SNT-TC-1 A as amended by IWA-2300 of the 1986 Edition of ASME Section XI for the qualification and certification of NDE personnel. Like CP-189, SNT-TC-1 A does not address the visual examination method. lWA-2300(b) requires that personnel performing examinations not covered by SNT-TC-1 A (e.g. visual examinations) be qualified and certified to comparable levels of qualification as defined in SNT-TC-1 A and the Employer's written practice. The DBNPS written practice addresses the qualification of Level I, Level II, and Level 111 visual examination. This program requires minimum education, experience, and training requirements for these personnel. In addition, visual examination personnel performing containment examinations receive specific training in conducting containment examinations. Prior to certification, Level I and Level II visual and UTT examination personnel must successfully complete general, specific, and practical examinations to demonstrate their capability. Level III personnel must successfully complete a basic, method, and specific l
examinations. Recertification by examination is required every three years for Level I and Level 11 personnel and every five years for Level 111 personnel. Vision examinations to verify the visual acuity of Level I, Level II, and Level III personnel are performed upon initial qualification and annually thereafter.
I Docket Numbcr 50-346 License Number NPF-3 i
Serial Number 2529 i
,, Attachment Page 3 This written practice, based on the 1986 ASME Section XI IWA-2300 requirements, I
along with the containment specific training required will ensure that examination.
l personnel have the capability to detect conditions that may affect the containment structural integrity or leak tightness. Additionally, these visual examinations are l
controlled by the examination procedure requirements, i.e., illumination, resolution, etc.,
l required by IWE-2210 of the 1992 Edition and Addenda as modified by 10 CFR 50.55a.
This adds further assurance that these examinations are capable of detecting containment discontinuities.
C. Relief Request RR-E3, Containment Inspection Preservice of Reapplied Paint or Coatings and RR-E4, Containment Inspection VT Prior to Paint or Coating Removal
- 1. NRC Request:
"RR-E3 and E4: In the basis for relief section for these two relief requests, you state the Davis-Besse coating maintenance program will provide adequate level of safety and quality. With respect to the DBNPS coating program, please provide the following information related to the Service Level I coating (that is, protective coating (s) used inside the containment):
Standards, procedures, or guidelines used for (1) surface preparation, application, surveillance, and maintenance activities for protective coatings, and (2) documenting the quality and condition of reapplied paint. Maintenance activities include reworking of degraded coating, removing of degraded coating to sound coatio reparing the surface, applying new coating, and verifying the coating quality."
- 2. Toledo Edison Response:
The coatings on the interior surface of the containment vessel are considered nuclear safety related. They are applied and inspected in accordance with the NRC approved DBNPS 10 CFR 50 Appendix B Quality Assurance Program. This program is described in Chapter 17.2 of the DBNPS Updated Safety Analysis Report (USAR). Table 17.1-1 endorses NRC Regulatory Guide 1.54,6/73, Quality Assurance Requirements for Protective Coatings Applied to Water-Cooled Nuclear Power Plants, and ANSI Standard N101.41972, Quality Assurance Protective Coatings Applied to Nuclear Facilities. The following requirements are applicable for coatings applied to the interior surface of the l
containment vessel:
The quality assurance requirements of Section 3 of ANSI N101.4 applicable to the coating manufacturer are imposed on the coating manufacturer through the procurement process.
Docket Number 50-346 License Number NPF-3 Serial Number 2529
. /\\ttachrnent Page 4 Coating application procedures are developed based on the manufacturer's e
recommendations for application of the selected coating systems, Coating applicators are qualified to demonstrate their ability to satisfactorily apply the e
coatings in accordance with the manufacturer's recommendations.
Quality Control personnel perform inspections to verify conformance of the coating e
application procedures. Section 6 of ANSI N101.4 is used as a guideline in the establishment of the inspection program.
Quality Control inspection personnel are qualified to the requirements of Regulatory Guide 1.58, Rev 1.
Documentation demonstrating conformance to the above is maintained.
The condition orthe coatings are examined every 4 to 6 years in accordance with 10CFR50.65, " Requirements for Monitoring Effectiveness of Maintenance at Nuclear Power Plants." The general visual examination required by IWE is also performed each period. These periodic examinations will identify evidence of flaking, blistering, peeling, discoloration, or other signs of coating distress which might be indicative of degradation of the containment structural integrity.
This program is presently being evaluated against the recom.mendations ofInformation Notice (IN) 97-13," Deficient Conditions Associmed with Protective Coatings at Nuclear Power Plants," and the Electric Power Research Institute (EPRI) Plant Support Engineering Guidelines for Nuclear Safety Related Coatings. Changes to improve this program will be implemented as necessary.
D. Relief Request RR-E6, Containment Inspection Successive Examinations After Repair
- 1. NRC Request:
"RR-E6: You are requesting the relief from the requirements ofIWE-2420(b) and (c),
related to successive inspections. The request does not provide any discussion of quality and safety, when the flaws and degradation areas are accepted by engineering analysis (IWE-3122.3). Discuss your plans for monitoring the progression of the flaws and degradation areas when they are accepted by engineering analysis."
- 2. Toledo Edison Response:
Relief Request RR-E6 does not apply to flaws or degraded areas accepted by engineering analysis. It only applies to areas repaired in accordance with ASME Section XI acceptance criteria. Class 1,2, and 3 components that are repaired and meet these i
i j
Docket Number 50-346 License Number NPF-3 Serial Number 2529
.,Attachpient Page 5 requirements do not require successive inspections. Successive inspections in accordance with IWE-2420(b) and (c) will be performed on containment flaws or degraded areas which are accepted by engineering analysis.
l l
E. Relief Request RR-E7, Containment inspection Bolt Torque or Tension Testing l
- 1. NRC Request:
l "RR-E7: Before processing this relief request, the staff needs to know how the preload l
and condition of the bolts of the pressure-unseating containment penetrations (which would tend to induce tension in the bolts under accident conditions) are monitored and maintained. Provide a summary of such penetrations in the Davis-Besse containment and l
procedures used to monitor and maintain the functionality of their bolts."
- 2. Toledo Edison Response:
The DBNPS understands that a pressure-unseating containment penetration is a l
penetration which has a blind flange installed on the outside of a containment penetration l
and the blind flange is subjected to containment pressures. If a blind flange is installed on both the inside and outside of the containment, the penetration is not considered a pressure-unseating containment penetration. Penetrations which are pressurized, such as electrical penetrations, are also not considered pressure-unseating containment penetrations.
The DBNPS has no pressure-unseating containment penetrations.
l i