ML12151A120

Davis-Besse, Unit 1, Supplemental Reply to Request for Additional Information for the Review of the License Renewal Application (TAC ME4640) and License Renewal Application Amendment No. 26

ML12151A120
Person / Time
Site:	Davis Besse
Issue date:	05/25/2012
From:	Allen B S FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-12-185
Download: ML12151A120 (10)

Text

FENOC0E-% 5501 North State Route 2FirstEnergy Nuclear Operating Company Oak Harbor, Ohio 43449Barry S. Allen 419-321-7676Vice President -Nuclear Fax. 419-321-7582May 25, 2012L-12-185 10 CFR 54ATTN: Document Control DeskU. S. Nuclear Regulatory CommissionWashington, DC 20555-0001

SUBJECT:

Davis-Besse Nuclear Power Station, Unit No. 1Docket No. 50-346, License Number NPF-3Supplemental Reply to Request for Additional Information for the Review of theDavis-Besse Nuclear Power Station, Unit No. 1, License Renewal Application(TAC No. ME4640) and License Renewal Application Amendment No. 26By letter dated August 27, 2010 (Agencywide Documents Access and ManagementSystem (ADAMS) Accession No. ML102450565), FirstEnergy Nuclear OperatingCompany (FENOC) submitted an application pursuant to Title 10 of the Code of FederalRegulations, Part 54 for renewal of Operating License NPF-3 for the Davis-BesseNuclear Power Station, Unit No. 1 (DBNPS). By letter dated August 11, 2011(ML1 1216A236), the Nuclear Regulatory Commission (NRC) issued request foradditional information (RAI) 4.3.2.3.2 (Supplement), to complete its review of theLicense Renewal Application (LRA). By letter dated October 7, 2011 (ML1 1285A064),FENOC responded to the RAI by providing a commitment to perform a fatigue evaluationof selected Class 1 valves and submit an amendment to the LRA.The actions described in the commitment have been completed. The Attachmentprovides a supplemental response to NRC RAI 4.3.2.3.2 (Supplement), including adescription of the Class 1 valve fatigue evaluations performed and results obtained. TheNRC request is shown in bold text followed by the FENOC response.The Enclosure provides Amendment No. 26 to the DBNPS LRA.

Davis-Besse Nuclear Power Station, Unit No. 1L-1 2-185Page 2There are no regulatory commitments contained in this letter. If there are any questionsor if additional information is required, please contact Mr. Clifford I. Custer, FleetLicense Renewal Project Manager, at 724-682-7139.I declare under penalty of perjury that the foregoing is true and correct. Executed onMay_2, 2012.Sincerely,Barry S en

Attachment:

Supplemental Reply to Request for Additional Information for the Review of theDavis-Besse Nuclear Power Station, Unit No. 1 (DBNPS), License RenewalApplication, Section 4.3.2

Enclosure:

Amendment No. 26 to the DBNPS License Renewal Applicationcc: NRC DLR Project ManagerNRC Region III Administratorcc: w/o Attachment or EnclosureNRC DLR DirectorNRR DORL Project ManagerNRC Resident InspectorUtility Radiological Safety Board AttachmentL-12-185Supplemental Reply to Request for Additional Information for the Review of theDavis-Besse Nuclear Power Station, Unit No. 1 (DBNPS), License Renewal Application,Section 4.3.2Page 1 of 3Section 4.3.2Question RAI 4.3.2.3.2 (Supplement)

Background:

By letter dated June 22, 2011, the applicant responded to RAI 4.1-1 regardingcumulative usage factor (CUF) or It fatigue analyses for Class 1 valves. In itsresponse to RAI 4.1-1, Request 1, Part A, the applicant identified 12 large boreClass 1 valves (i.e., valves with nominal pipe sizes in excess of 4-inches) thatshould have received CUF or It fatigue analyses in accordance with the designcodes (i.e., 1971 or more recent Editions of the ASME Code Section III, or the1968 Edition of the Draft ASME Pump and Valve Code for Nuclear Power Plants).The applicant provided Commitment No. 46 to complete the following, prior toApril 22, 2015:FENOC commits to perform a fatigue evaluation in accordance withthe requirements of the ASME Code of record for the Davis-BesseClass 1 valves that are greater than 4 inches nominal pipe size. Theapplicable valve identification numbers are CF28, CF29, CF30, CF31,DH76, DH77, DH11, DH12, DHIA, DHIB, DH21, and DH23.LRA Section 4.3.2.3.2, as amended by letter dated June 22, 2011, states that thefatigue analyses for these 12 referenced large bore Class I valves are as TLAAsand are dispositioned in accordance with Title 10 of the Code of FederalRegulations 54.21(c)(1)(iii), that the effects of fatigue on Class 1 valves greaterthan 4 inches diameter nominal pipe size will be managed for the period ofextended operation by the Fatigue Monitoring Program. LRA Section 4.3.2.3.2also states that the issue with the missing CUF or It calculations for the12 referenced large bore Class 1 valves has been entered into the applicant'sCorrective Actions Program.Issue:The information provided by the applicant in letter of June 22, 2011, did notprovide information regarding whether the applicant had any ASME Code,Section III NB-3222.4(d) fatigue waiver assessments (or equivalent waiverassessments permitted by the 1968 Draft ASME Pump and Valve Code) for the12 large bore Class 1 valves referenced in Commitment No. 46. Therefore, the AttachmentL-12-185Page 2 of 3staff requests additional information regarding whether fatigue calculations arerequired for these valves.The staff is concerned that without the CUF or It analyses or an appropriatefatigue waiver or exemption for these 12 large bore Class 1 valves, the staff wouldnot be able to evaluate whether the aging effects will be appropriately managedby the commitment.Request:Provide justification for not having the analyses for staff review as part of theLRA, or provide your appropriate fatigue waiver or fatigue exemption bases fornot having such analyses.RESPONSE RAI 4.3.2.3.2 (Supplement)In response to RAI 4.3.2.3.2 (Supplement) submitted by letter dated October 7, 2011(ML1 1285A064), FENOC provided the following commitment:FENOC will perform a fatigue evaluation in accordance with therequirements of the ASME Code of record for the Davis-Besse Class 1valves that are greater than 4 inches diameter nominal pipe size. Theapplicable valve identification numbers are CF28, CF29, CF30, CF31, DH76,DH77, DH11, DH12, DH1A, DH1B, DH21 and DH23. LRA Sections 4.3.2.3.2and A.2.3.2.13, both titled "Class 1 Valves Fatigue," will be revised to includethe results of the fatigue evaluations, and these changes will be submitted asan amendment to the Davis Besse LRA no later than May 31, 2012.The actions described in the commitment have been completed. This supplementalresponse to RAI 4.3.2.3.2 (Supplement) addresses the fatigue evaluation results ofthe Davis-Besse Class 1 valves that are greater than 4 inches diameter nominal pipesize (valve identification numbers CF28, CF29, CF30, CF31, DH76, DH77, DH1 1,DH12, DHIA, DH1B, DH21 and DH23) and the associated changes to License RenewalApplication (LRA) Sections 4.3.2.3.2 and A.2.3.2.13.Fatigue analyses were prepared for the subject Class 1 valves in accordance withparagraph NB-3550 of ASME Code Section III, 1974 Edition with Addenda through theSummer of 1976, and were reconciled to the valve construction code year. Thecumulative usage factors (CUFs) calculated for the subject Class 1 valves are based onnuclear steam supply system design transients and, as shown in the table below, areless than 1.0. The number of occurrences of design transients is tracked by the FatigueMonitoring Program to ensure that action is taken before the design cycles are reached.Therefore, the effects of fatigue on Class 1 valves greater than 4 inches diameter AttachmentL-12-185Page 3 of 3nominal pipe size (NPS) will be managed for the period of extended operation by theFatigue Monitoring Program in accordance with 10 CFR 54.21(c)(1)(iii).Size Construction MaximumValve ID (dia. NPS) Code Year CUF& TypeCF28CF29 14 inch 1971 Core Flood -w/Addenda thru core flood tank discharge line 0.02839CF30 Winter 1972 stop check isolation valveCF31DHI 1 12 inch 1968 Reactor Coolant System to Decay Heat- 0.14594gate Draft Pump & containment isolation valveDH12 gValveDH21 8 inch 1971 Reactor Coolant System to Decay Heat -w/Addenda thru containment isolation valve bypass line 0.02732DH23 gate Winter 1972 isolation valveDH76 10 inch 1971 Low Pressure Injection tow/Addenda thru Reactor Coolant System -0.14099DH77 Winter 1972 stop check isolation valveDH1A 10 inch 1968 Low Pressure Injection -gate Draft Pump & outside containment isolation valve 0.18261DH1Bgt ValveLRA Sections 4.3.2.3.2 and A.2.3.2.13 are revised to include the results of the fatigueevaluations.See the Enclosure to this letter for the revision to the DBNPS LRA.

EnclosureDavis-Besse Nuclear Power Station, Unit No. 1 (DBNPS)Letter L-12-185Amendment No. 26 to theDBNPS License Renewal ApplicationPage 1 of 5License Renewal ApplicationSections AffectedSection 4.3.2.3.2Section A.2.3.2.13The Enclosure identifies the change to the License Renewal Application (LRA) byAffected LRA Section, LRA Page No., and Affected Paragraph and Sentence. Thecount for the affected paragraph, sentence, bullet, etc. starts at the beginning of theaffected Section or at the top of the affected page, as appropriate. Below each sectionthe reason for the change is identified, and the sentence affected is printed in italics withdeleted text hined-ou and added text underlined.

EnclosureL-12-185Page 2 of 5Affected LRA Section LRA Page No. Affected Paragraph and Sentence4.3.2.3.2 Pages 4.3-16 Entire Sectionand 4.3-17In response to RAI 4.3.2.3.2 (Supplement), LRA Section 4.3.2.3.2, "Class 1Valves Fatigue," previously revised by FENOC letter dated October 7, 2011(ML1I1285A064), is replaced in its entirety, to read as follows:4.3.2.3.2 Class 1 Valves FatigueThe ASME Code requires a fatigue evaluation for Class 1 valves greater than 4inches diameter nominal pipe size or for valves less than or equal to 4 inches innominal pipe size if specified by the owner's design specification. TheDavis-Besse purchasing specifications did not require a fatigue analysis forClass 1 valves less than or equal to 4 inches in nominal pipe size. Therefore,only valves greater than 4 inches diameter nominal pipe size require a fatigueanalysis. Piping and instrumentation diagrams (P&IDs) were reviewed to identifyClass 1 valves of greater than 4 inches diameter nominal pipe size. There were12 valves of greater than 4 inches diameter nominal pipe size that were identifiedas a result of this effort.Fatigue analyses were prepared for the subject Class 1 valves in accordancewith paragraph NB-3550 of ASME Code Section III, 1974 Edition with Addendathrough the Summer of 1976 and were reconciled to the valve constructioncode year.Since ASME Code fatigue analyses evaluate an explicit number and type ofthermal and pressure transients that are postulated to envelope the number ofoccurrences possible during the design life of the plant, these fatigue analysesare time-limited aging analyses (TLAAs) and therefore, are required to beevaluated in accordance with 10 CFR 54.21(c)(1).The cumulative usage factors calculated for the subject Class 1 valves are basedon nuclear steam supply system design transients and, as shown in the tablebelow, are less than 1.0. The number of occurrences of design transients istracked by the Fatigue Monitoring Program to ensure that action is taken beforethe design cycles are reached. Therefore, the effects of fatigue on Class 1 valvesgreater than 4 inches diameter nominal pipe size (NPS) will be managed for theperiod of extended operation by the Fatigue Monitoring Program.

EnclosureL-12-185Page 3 of 5Size Construction MaximumValve ID (dia. NPS) Code Year Description CUF& TypeCF28CF29 14 inch 1971 Core Flood -w/Addenda thru core flood tank discharge line 0.02839CF30 Winter 1972 stop check isolation valveCF31Draft1968 Reactor Coolant System to Decay Heat -DH12 gate Valv containment isolation valve 0.14594DH12 ValveDH21 8 inch 1971 Reactor Coolant System to Decay Heat -w/Addenda thru containment isolation valve bypass line 0.02732DH23 gate Winter 1972 isolation valveDH76 10 inch 1971 Low Pressure Injection tow/Addenda thru Reactor Coolant System -0.14099DH77 Winter 1972 stop check isolation valveDDrf1A 10 inch 1968 Low Pressure Injection -gae Draft Pump & outside containment isolation valve 0.18261DH-11B at ValveDisposition: 10 CFR 54.21(c)(1)(iii)The effects of fatigue on Class I valvesgreater than 4 inches diameter nominalpipe size will be managed for the periodof extended operation by the FatigueMonitoring Program.

EnclosureL-1 2-185Page 4 of 5Affected LRA Section LRA Paqe No. Affected Paragraph and SentenceA.2.3.2.13 Page A-41 Entire SectionIn response to RAI 4.3.2.3.2 (Supplement), LRA Section A.2.3.2.13, "Class 1Valves Fatigue," previously revised by FENOC letter dated October 7, 2011(ML1I1285A064), is replaced in its entirety, to read as follows:A.2.3.2.13 Class 1 Valves FatigueThe ASME Code requires a fatigue evaluation for Class 1 valves greater than 4inches diameter nominal pipe size or for valves less than or equal to 4 inches innominal pipe size if specified by the owner's design specification. TheDavis-Besse purchasing specifications did not require a fatigue analysis forClass 1 valves less than or equal to 4 inches in nominal pipe size. Therefore,only valves greater than 4 inches diameter nominal pipe size require a fatigueanalysis. Piping and instrumentation diagrams (P&IDs) were reviewed to identifyClass 1 valves of greater than 4 inches diameter nominal pipe size. There were12 valves of greater than 4 inches diameter nominal pipe size that were identifiedas a result of this effort.Fatigue analyses were prepared for the subject Class 1 valves in accordancewith paragraph NB-3550 of ASME Code Section III, 1974 Edition with Addendathrough the Summer of 1976 and were reconciled to the valve constructioncode year.Since ASME Code fatigue analyses evaluate an explicit number and type ofthermal and pressure transients that are postulated to envelope the number ofoccurrences possible during the design life of the plant, these fatigue analysesare time-limited aging analyses (TLAAs) and therefore, are required to beevaluated in accordance with 10 CFR 54.21(c)(1).The cumulative usage factors calculated for the subject Class 1 valves are basedon nuclear steam supply system design transients and, as shown in the tablebelow, are less than 1.0. The number of occurrences of design transients istracked by the Fatigue Monitoring Program to ensure that action is taken beforethe design cycles are reached. Therefore, the effects of fatigue on Class 1 valvesgreater than 4 inches diameter nominal pipe size (NPS) will be managed for theperiod of extended operation by the Fatigue Monitoring Program in accordancewith 10 CFR 54.21 (c)(1)(iii).

EnclosureL-12-185Page 5 of 5size Construction MaximumValve ID (dia. NPS) Code Year Description CUF& TypeCF28CF29 14 inch 1971 Core Flood -w/Addenda thru core flood tank discharge line 0.02839CF30 Winter 1972 stop check isolation valveCF31Draft1968 Reactor Coolant System to Decay Heat -DH1g Draft Pump & containment isolation valve 0.14594DH12 gaeValveDH21 8 inch 1971 Reactor Coolant System to Decay Heat -w/Addenda thru containment isolation valve bypass line 0.02732DH23 gate Winter 1972 isolation valveDH76 10 inch 1971 Low Pressure Injection tow/Addenda thru Reactor Coolant System -0.14099DH77 Winter 1972 stop check isolation valveDH1A 10 inch 1968 Low Pressure Injection -Dae Draft Pump & outside containment isolation valve 0.18261DH-11B at Valve III