ML102950176
| ML102950176 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 04/27/2010 |
| From: | Richard Ennis Office of Nuclear Reactor Regulation |
| To: | Conte R NRC Region 1 |
| References | |
| FOIA/PA-2010-0334 | |
| Download: ML102950176 (5) | |
Text
Burritt, Arthur From: Ennis, Rick Sent: Tuesday, April 27, 2010 11:40 AM To: Conte, Richard Cc: Elliott, Robert; OHara, Timothy; Tsao, John; Lupold, Timothy; Manoly, Kamal; Burritt, Arthur; Cahill, Christopher; Schmidt, Wayne; Chernoff, Harold; Schulten, Carl; Cline, Leonard; Schroeder, Daniel; Balian, Harry; Honcharik, Michelle; Bowman, Eric; Miller, Barry
Subject:
Salem AFW Piping Testing Rich, As follow-up to our discussion this morning regarding the Salem AFW piping pressure tests required by IWA-5244 and Salem surveillance requirement (SR) 4.0.5, I did some research on the NRC staff position related to whether the missed surveillance provisions of Salem SR 4.0.3 are applicable to surveillances which have never been performed (i.e., versus surveillances that were "missed").
The Pilgrim TIA dated 1/23/09 (ML083660174) states that "the NRC staffs position is that a missed SR is different than an SR that was never performed." Some of the key points in the TIA supporting this position are as follows:
- 1) Use of the word "frequency" [in SR 4.0.3] establishes an interval, a period of time, that includes an initial performance of the SR, and a specified time period to re-perform the SR thereafter, i.e,, to repeat the surveillance.
- 2) SRs are performed at frequencies that are more often than the mean-time to failure of particular systems.
Thus, most SRs confirm that SSCs are operable given an operable finding at the previous testing interval.
On 2/24/09 a public meeting was held between the NRC staff and the industry Technical Specification Task Force (TSTF). As discussed in the meeting summary dated 3/24/09 (ML090700535):
!The TSTF began a discussion of SR 3.0.3 [SR 3.0.3 for Standard Technical Specifications (STS) is same as SR 4.0.3 for Salem] and stated that a SR that has never been performed should be treated like a missed SR.
The staff stated that a missed SR is not the same as a never performed SR, therefore SR 3.0.3 cannot be applied to a never performed SR. The TSTF stated that it does not agree with a December2008 TIA on the subject. The TSTF stated that a TIA from 1992 conflicts with the December 2008 TIA. The staff requested that the TSTF forward a copy of the 1992 TIA to NRC. The TSTF stated that licensees must state why they feel the system will pass a SR in order to ask for an SR 3.0.3 extension for a portion of a system that has never been tested. The staff agreed with the TSTF that a framework for treatment of "never performed SRs" could be developed. The staff stated its belief that this approach was the best way to resolve the differences in position between the staff and the industry on this topic."
By letter dated 5/1/09 (ML090230254),.the NRC staff did not.accept for review an industry proposal (TSTF-512) that would approve a change to the STS. The change proposed by the TSTF would have revised the STS to establish a new position interpreting surveillances that never were performed as'equivalent to surveillances whose test intervals are inadvertently exceeded.
In subsequent discussions with the NRC staff, the TSTF indicated that TSTF-512 would be resubmitted to the NRC providing additional justification for its position. I talked to Carl Schulten in NRR's Tech Spec Branch and he confirmed that the TSTF has not submitted a revised proposal. In addition, Carl confirmed that the current NRC staff position is as stated in the Pilgrim TIA.
Bottom line, PSEG's use of SR 4.0.3 to justify a delay in performing a surveillance that has never been nQr;rmed is contrary to our current interpretation on use of SR 4.0.3.
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Please let me know if you have any questions.
thanks, Rick 301-415-1420
Original Message----
From: Conte, Richard Sent: Monday, April 26, 2010 5:11 PM To. OHara, Timothy; Tsao, John; Lupold, Timothy; Manoly, Kamal; Burritt, Arthur; Cahill, Christopher; Schmidt, Wayne Cc: Ennis, Rick; Elliott,. Robert
Subject:
Need for conference call RE: FEA of Degraded Salem Unit 1 AFW Piping we are looking to do a conference call on Wednesday at 300pm or 330 NLT 400pm to go over what we know about the number of documents that have come in. we think Unit 1 can safely startup in light of repairs and code compliance.
Hdqtrs is reviewing the FEA that will be used to support at Unit 1 past operability determination and root cuase report. not sure when the later two documents will be in but they are not needed for Unit 1 starup.
There is a tech eval on reduced rated pressure to 1275 that was reviewed also in order to support the past operability review. Not sure how it applies to Unit 2.
Unit 2 current operability and risk assessment (with 1.25 year exposure time on risk) is in on draft and we plan to engage licensee representatives tomorrow on what information supports the Jan 21, 2010 start fo the 1.25 years to the outage next spring in 2011.
Bottom line is looks like back in the construction days, Unit 2 was properly coated but Unit 1 was not, No definitive answers yet as to why, based on desing or documented as left or as found condition back in the 1970s.
We are also trying to deal with the acceptablilty of the Unit 2 operability determination based on an ASME pressure test that was never done and operational information that support flow measurements but may not be considered the alternate ASME unabated flow test per the same code.
With respect to the previous paragraph, a TIA on Pilgirm (ml 083660174) from ITSB seems to accept, partially, an industry position that the test can be deferred ifthere is a basis that the test will pass - still a violation for which we could issue NCV is green (preferred) or exercise enforcement discretion (least preferred since they were caught on this issue). Not sure the flow information (not test) is as sensitive as the pressure drop but then again the coating issue seems to be different from Unit 1. I need to talk to someone in TS branch and or Lupold on this issue, perhaps tomorrow before the conference call - what is a reasonable expectation that the pressure drop test will pass in the spring of next year? When we get a less draft oper det. we can forward it.
-Original Message----
From: OHara, Timothy Sent: Monday, April 26, 2010 4:47 PM To: Conte, Richard
Subject:
FW: FEA of Degraded Salem Unit 1 AFW Piping Importance: High 2
- Rich, Tim Lupold has asked John Tsao to forward the FEA to Kamal Manoly for review.
-,---Original Message -----
From: Tsao, John Sent: Monday, April 26, 2010 4:15 PM To: Manoly, Kamal Cc: Lupold, Timothy; OHara, Timothy
Subject:
FW: FEA of Degraded Salem Unit I AFW Piping Importance: High
- Kamal, Tim O'Hara of Region I forwarded me the FEA report for the Salem buried AFW piping. Tim Lupold asked me to forward the FEA report to you (see the first attached file). Attachment No. 2 is my assessment of the FEA report that I sent to Tim O'Hara this morning. Attachments No. 3 and 4 are the preliminary information for the FEA report.
Thanks.
John
Original Message----
From: OHara, Timothy Pent: Friday, April 23, 2010 2:23 PM To: Tsao, John Cc: Lupold, Timothy; Conte, Richard; Gray, Harold; Burritt, Arthur; Schroeder, Daniel; Balian, Harry; Cline, Leonard; Sanders, Carleen; Ennis, Rick
Subject:
FEA of Degraded Salem Unit. 1 AFW Piping Importance: High Hello John, Here is the FEA we've been discussing. Note that PSEG is still reviewing but they have provided this copy which will most likely not change. Please review this and let us know what you think. Thanks.
Tim OHara
--- -Original Message -----
From: Berrick, Howard G. [1]
Sent: Friday, April 23, 2010 2:11 PM To: Schroeder, Daniel L.; OHara, Timothy
Subject:
Evaluation of Degraded Underground Auxiliary Feedwater Piping (SIA Report 1000494_301 _RC)
Importance: High Attached ids the SIA Report RE: Evaluation of Degraded Underground Auxiliary Feedwater Piping Please note: This report has not been through the PSEG Owners Acceptance or Third Party Review process.
Howard Berrick PSEG Nuclear LLC 3
Slern Regulatory Assurance PSEG Nuclear - Salem Generating Stations (W) 856-339-1862 c-- . jn-S(a l(b)(6)
(Fax) o n4 A
- L-_Bpr)I
<<1000494_301_RC.doc>>
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4
APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL MODES or other specified conditions in the Applicability for individual Limiting Conditions for Operation, unless otherwise stated in the Surveillance Requirement. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the Limiting Condition for Operation. Failure,.to.,per.form a Surveillance.
ithin the 'pecifiýqed*.fre u
- shall be failure, to meet the Limiting,,ondith4 n for o 7PS-17-os e pt Ied inS Surveillances do not have to be performed od inoperable equipment or variab les outside specified limits'.
4.0,2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25 percent of the specified.surveillance interval.
4.0.3 If it is discovered that a Surveillance was not performed within its specified frequency, then complianc e with the requirement to declare the Limiting Condition for Operation not met may be delayed, from ihe time of discovery, up to
,24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified frequency, whi*chever is greater.
This delay period is permitted to a*low performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.
If the Surveillance is not performed within the delay period, the Limiting Condition for Operation must immediately be declared not met and the applicable Actions must be entered.
When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition for Operation must immediately be declared not met and the applicable Actions must be entered.
4.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 4.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shallonly be made in accordance with LCO 3.0.4.
This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of-the unit.
4 . 0.5 Surveillance Requirements for iRservice inspection and testinkpof NSME Code Class 1, 2 and 3 components shall-be applicable as follows:.
- a. Inservice Pi.spectio'n of ASME Code Class 1, 2 and 3 components and inservice testing of ASME Code Class 1, 2 and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant-to 10 CFR 50, Section 50.55a(g) (6) (i)
- b. Surveillance intervals specified in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda for the inservice inspection and testing activities required by the ASME Boiler and Pressure Vessel Code and applicable Addenda shall be applicable as follows in these Technical Specifications:
SALEM - UNIT 2 3/4. 0-2a Amendment No, 258