ML102980342
| ML102980342 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 05/07/2010 |
| From: | Conte R NRC Region 1 |
| To: | Richard Ennis, Modes M, O'Hara T Office of Nuclear Reactor Regulation, NRC Region 1 |
| References | |
| FOIA/PA-2010-0334 | |
| Download: ML102980342 (3) | |
Text
Conte, Richard From:
Conte, Richard Sent:
Friday, May 07, 2010 145PM To:
Ennis, Rick; OHara, Timothy; Modes, Michael Cc:
Burritt, Arthur; DeFrancisco, Anne; Farrar, Karl; Patnaik, Prakash; Taylor, Robert; Chernoff, Harold; Schulten, Carl; Tsao, John; Manoly, Kamal; Bowman, Eric; Lupold, Timothy
Subject:
Review of PSEG Amd Request - RE: Salem Violation Consensus Rick thanks for the ml No. 092790463 on the amendent request. Its purpose appears to be to remove ISI per code completely out of TS because it is redundant to code and rule. It is also to put IST for pumps and valves as a program in the admin section of TS which is to be also consistent with the code for IST. You noted I believe a problem with the Unit 2 page for TS 3.4.11.1 on Class 1 to 2 and 3 structural integrity in that it did not remove the ISI reference. I note or could not find a corresponding page change for Unit 1 for TS 3.4.11.1 An interesting question, how do you write the LCO for structural integrity without referencing ISI of the code or rule or using the words shall be maintained (LCO sounds like a surveillance which it isn't).
From: Ennis, Rick Sent: Friday, May 07, 2010 7:02 AM To: Conte, Richard; OHara, Timothy; Modes, Michael Cc: Burritt, Arthur; DeFrancisco, Anne; Farrar, Karl; Lupold, Timothy; Patnaik, Prakash; Taylor, Robert; Chernoff, Harold; Schulten, Carl; Tsao, John; Manoly, Kamal; Bowman, Eric; Schroeder, Daniel; Balian, Harry; Cline, Leonard
Subject:
RE: Salem Violation Consensus I've copied Pat Patnaik and Rob Taylor on this email since, if a relief is submitted, I believe Pat would likely be the reviewer. Pat - based on our discussions last week, please confirm that you think a relief request is needed to justify not performing the IWA-5244 pressure test on the Salem 2 buried AFW piping until the next outage.
Rich - I agree with your assessment that it's not clear that there is a TS violation. Carl/Eric - do you agree?
It's also not clear if there is a lack of structural integrity on the Salem 2 buried AFW piping. John/Kamal - do you agree?
- Thanks, Rick From: Conte, Richard Sent: Friday, May 07, 2010 6:13 AM To: OHara, Timothy; Modes, Michael Cc: Ennis, Rick; Burritt, Arthur; DeFrancisco, Anne; Farrar, Karl; Lupold, Timothy
Subject:
RE: Salem Violation Consensus I vote Nah. In sum, I am not sure the Aye votes fully appreciate the ramifications of being beyond the structural integrity LCO when we all agreed it is ok to wait for them to do the test next outage. Using the NOED process which will be forced on the licensee since they do not plan to shutdown sounds like bureacratic response to this issue as unnecessary.
I am guided by 50.55a and the code not the TS with all of its nuiances for which there is a TS amendment to fix it.
The operability guidance presumes operability and gives examples of not meeting code as examples of degraded, not being beyond the limits of the LCO.
We have a TIA that confirms ISI is not a surveillance requirement. The pressure drop test is clearly an NDE or ISI process.
Structural integiity is determined by meeting design, doing preservice NDE and testing, and maintaining it by Inservice. A failure to meet one test does not necessarily invalidate structural integrity.
As Harold said, even a failure of the test as noted by leak does not necessarily imply a loss of structural integrity, thus the IWA 4160 to evaluate for suitability in this case structural integrity which we told the license at the outbrief.
Salem TS is confusing in the above point; so how can we say it is violated.
We all anticipate this test when done is going to pass. It would have passed at Unit 1 with the known external degradation.
I do agree they need a code relief to cover the situation from now to the next outage - this appears to be the main issue in all of this as a reasonable next step.
That is the relief is not to cover the failure to do the test in the first two periods of the interval, that would condone the violation and turn it into acceptable status should the relief be approved on those grounds..
Since I have the alternate view and Darrell loves listening to alternate views I will try to set up something today with Darrell. Harold and Tim it sounds like you will be available to to discuss with him so I don't prejudice any view.
I will let you know what time. How is this; Darrell is acting RA.
I do agree with Rick Ennis; this is all as clear as mud; but thanks for your help.
In an open collaborative work environment I would propose we get guidance form the Acting RA and bring the views to Lupold and company on Monday. I would not set up anything with PSEG just yet.
I plan to call Len Rajkowski today to better understand what they view are the degraded LCOs Art Burritt if you are in the office today, you are welcome to join us.
I still don't have an immediate safety issue; nothing indicates otherwise in these emails.
I added Tim Lupold as a heads up.
From: OHara, Timothy Sent: Thursday, May 06, 2010 9:42 PM To: Modes, Michael; Conte, Richard Cc: Ennis, Rick; Burritt, Arthur; DeFrancisco, Anne; Farrar, Karl
Subject:
RE: Salem Violation Consensus
- Rich, I think this is the best way to handle the situation and address all the possibilities.
2
I propose we arrange a call with PSEG on Monday to communicate the following:
(1) "clarify" the preliminary violation we informed them about at the Debrief on Wednesday with the details (below), i.e. add that they are in violation of the structural integrity tech. spec. and, (2) inform PSEG that a relief request explaining the missed "inservice inspections (pressure tests)" will be needed to eventually restore compliance (when approved by NRR).
I'll be working at home on Monday and I'll be available to lead the call or participate. I can call Howard Berrick on Friday to ask him to coordinate the PSEG people for a Monday call if you want. Please keep me involved in what happens on this so that I get the violation and report correct.
Tim OHara From: Modes, Michael Sent: Thursday, May 06, 2010 4:15 PM To: Conte, Richard Cc: OHara, Timothy; Ennis, Rick; Burritt, Arthur; DeFrancisco, Anne; Farrar, Karl
Subject:
Salem Violation Consensus We are going to site the regulation 50.55a In turn the ASME requirement they did not comply with.
This will then result in a failure to show structural integrity.
We will cover the absence of a NOED by also citing, concurrently, the tech spec violation as a subtier of the violation.
We will issue an NOV (with 30 day reply) if they have not submitted the relief request by the time we issue the report in order to faciliate the correct behavior.
If NRR has the request in hand we will issue this as non-cited.
As a secondary benefit we establish a precident for pressure testing and structural integrity for buried piping that will stand in the absence of the tech spec requirement. This tech spec requirement does not exist in Standard Tech Specs, nor will it last long in the Salem tech specs.
All in favor say "Aye".
The ayes have it... the motion carries.
3