IR 05000311/2016002

Withdrawal of Non-Cited Violation 05000311/2016002-02

ML17083B110
Person / Time
Site:	Salem
Issue date:	03/27/2017
From:	James Trapp Division of Nuclear Materials Safety I
To:	Sena P Public Service Enterprise Group
References
EA-16-244 IR 2016002
Download: ML17083B110 (3)

Text

March 27, 2017

SUBJECT:

WITHDRAWAL OF NON-CITED VIOLATION 05000311/2016002-02

Dear Mr. Sena:

In your letter dated October 24, 2016 (ML16298A1611), you contested a Green non-cited violation (NCV) that was documented in the Salem Nuclear Generating Station (Salem) second quarter 2016 integrated inspection report dated September 22, 2016 (ML16266A224). The NCV was against Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, and described a failure by Public Service Enterprise Group (PSEG) to follow the operability process as prescribed in PSEG procedures at Salem. Specifically, in April 2016, PSEG identified actual or potential degradation of approximately 23 percent of the baffle-former bolts in the Salem Unit 1 reactor vessel. A sufficient number of bolts are required to ensure proper core flow during normal and postulated accident conditions, and also to ensure that control rods can be inserted to shut down the reactor. PSEG entered the issue into the corrective action program and replaced the degraded bolts. PSEG also performed an immediate operability determination for Unit 2 in accordance with its procedure OP-AA-108-115, Operability Determinations and Functionality Assessments. However, PSEG concluded that while susceptible, there was no known direct evidence of a degraded or non-conforming condition on Unit 2 and that a more detailed operability evaluation of that unit was not required. The NRC did not agree with PSEGs basis for this conclusion and issued the violation as stated above.

Your October 24, 2016, letter provided an interpretation of PSEG procedure OP-AA-108-115 related to the baffle-former bolt condition that was different from the NRCs position as described in the inspection report, and requested that the violation be withdrawn. Your letter stated, in part, PSEGs determination that direct evidence of a degraded or non-conforming condition was required to necessitate the performance of a full operability evaluation per your procedure.

1 Designation in parentheses refers to an Agencywide Documents Access and Management System (ADAMS) accession number. Documents referenced in this letter are publicly-available using the accession number in ADAMS. In response to your letter, the NRC formed a panel to review the information you provided. The staff members involved were independent of the initial inspection effort. Based on a thorough review of the issue, the NRC has concluded that the violation as written cannot be supported.

Specifically, the independent review noted different steps within the procedure that could be interpreted to either support or refute PSEGs claim related to the need for direct evidence of a degraded or non-conforming condition. As a result of this potential for differing interpretations of your procedural requirements, the NRC has determined that it was not appropriate to issue a violation for a failure to comply with the procedure. Therefore, the NCV is hereby withdrawn, and we will modify our records accordingly.

The NRC acknowledges that the operability implications of operating experience on systems, structures, and components requires judgment, especially in cases where direct inspection and testing results are not readily available. Given the similarities between Unit 1 and Unit 2, and other operating plants where degradation was observed, a technically adequate assessment was warranted to affirm the presumption of operability of the emergency core cooling systems capability to provide long-term core cooling. While the NRC has determined that your initial technical evaluation of this condition dated June 15, 2016, relied on assumptions that were not fully supported, your operability determination dated July 26, 2016, did provide an adequate analysis to provide reasonable assurance of operability for the emergency core cooling system function until the next refueling outage when inspections could be performed. As such, the NRC does not plan any additional action related to this issue.

As you are aware, on September 29, 2016, the Nuclear Energy Institute (NEI) provided the NRC a letter related to this NCV (ML16274A473) which expressed the intention to clarify the conditions/criteria for entry into the operability process. As stated in our response to NEI (ML16293A951), the NRC staff looks forward to continued meaningful interactions with industry and the public to help ensure necessary and appropriate clarity in operability determination guidance.

This letter will be made available for public inspection and copying at http://www.nrc.gov/readingrm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

If you have any questions regarding this matter, please contact Mr. Raymond McKinley at (610) 337-5150.

Sincerely,

/RA/

James M. Trapp, Director Division of Nuclear Materials Safety

Docket No. 50-311 License No. DPR-75

cc: Distribution via ListServ SUBJECT:

WITHDRAWAL OF NON-CITED VIOLATION 05000286/2016002-02 DATED MARCH 27, 2017

DISTRIBUTION: (via email)

DDorman, RA

(R1ORAMAIL Res)

DLew, DRA

(R1ORAMAIL Res)

MScott, DRP

(R1DRPMAIL Res)

DPelton, DRP

(R1DRPMAIL Res)

RLorson, DRS

(R1DRSMAIL Res)

JYerokun, DRS

(R1DRSMAIL RES)

FBower, DRP RBarkley, DRP MDraxton, DRP SGhrayeb, DRP PFinney, DRP, SRI AZiedonis, DRP, RI COtt, DRP, AA JBowen, RI, OEDO RidsNrrPMSalem Resource RidsNrrDorlLpl1-2 Resource ROPreports Resource JTrapp, DNMS RMcKinley, DRS MGray, DRS

DOCUMENT NAME: G:\\DRS\\Plant Support Branch 1\\McKinley\\Salem Baffle Bolt\\Salem disputed NCV withdrawal letter Rev 1.docx ADAMS Accession Number: ML17083B110

SUNSI Review

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OFFICE RI/DRP RI/DRS RI/OE RI/ORA HQ/OE NAME FBower email RMcKinley BBickett BKlukan MMarshfield email DATE 3/17/17 3/18/17 3/21/17 3/20/17 3/21/17 OFFICE RI/DRP RI/DRS RI/DNMS

NAME MScott RLorson JTrapp

DATE 3/21/17 3/24/17 3/24/17

OFFICIAL RECORD COPY