ML102980530

Email from Ohara, Timothy to Conte, Richard, Et Al, Salem Unit 1 Notification 20459689.

ML102980530
Person / Time
Site:	Salem, Hope Creek
Issue date:	04/27/2010
From:	O'Hara T NRC Region 1
To:	Conte R NRC Region 1
References
FOIA/PA-2010-0334
Download: ML102980530 (3)

Text

OHara, Timothy f-,

From: OHara, Timothy Sent: Tuesday, April 27, 2010.2:24 PM To: Conte, Richard; Gray, Harold Cc: OHara, Timothy

Subject:

Salem Unit 1 Notification 20459689 Attachments: Scan File.pdf Harold & Rich, Attached is the notification on the missed pressure testing on the AFW pipe.

The ISI program is implemented by procedures. The 2 procedures listed in the notification are those needed to do the ASMW, IWA-5244 Buried Component tests. There is no direct reference to the AFW piping in the program because the program did not pick the piping up as buried.

Still checking on the time to report this, but I believe it is included in either 10 CFR 50.55(a) or the Code requirements someplace.

Tim OHara

---

Original Message -----

From: RlScan [1]

Sent: Tuesday, April 27, 2010 2:18 PM To: OHara, Timothy

Subject:

Scan from Salem/Hope Creek HP5035 Please open the attached document. This document was digitally sent to you using an HP Digital Sending device.

• • • • • • • • • • • • • • Long Text Object Identification**************

Notification 000.020459689 Long text 04/21/2010. 11:32:25 NUCLEARNOT (NUCLEARNOT)

Notification submitted by: Edley Giles 856-339-2271 ENTNBU\NUITG: AND ITS.

CONDITION DESCRIPTION/LOCATION (THE INAPPROPRIATE ACTION NEGATIVE EFFECT/INCLUDE A DETAILED LOCATION DESCRIPTION) :#

The req-uired ASME Section XI Pressure Te*sýtsing for the buried Axii:ry Feedwater piping required'by the ER-AA-33Q-001 and OU-AA-335-015 procedu~res were not performed. The ISI program manager has found no*

,ev~idence of testing :These, p~rocedures,s, i p~lemen~t 'the: .euirernlents o~f lO0CFR50.-55a. The system pressure test boundary drawing (S2-SPT-336-0) identifies the piping as YARD piping not buried piping. This is applicable to both Salem Units. The Salem unit 1 piping however is being replaced and will be hydro tested to code requirements prior to being placed in service.

ACTIVITIES, PROCESSES, PROCEDURES INVOLVED:

ER-AA-330-001,Section XI pressure Testing OU-AA-335-015, VT-2 Visual Examination WHY DID CONDITION HAPPEN?

The system pressure test boundary drawing ($2-SPT-336-0)Y identifies, the piping as YARD piping not buried piping. However, it is commonly understood that it is buried pipe.

CONSEQUENCES:

The implementation of the ASME Section XI pressure testing may.not have been completed in the current inspection interval as required. However, the in-service testing required by S2.OP-ST.AF-0007, In-service Testing of Aux Feed Water Valves Modes 4-6, infers that the functibonal requirements of the test have been met. The test records pi~mp dp'anid pump flow. The flow measurement occurs down stream of the'buried section of piping. The pump dp is taken at pump. This ST uses the 21 and 22 AF pumps. Review of the IST data taken (12 STs since May 1997) shows that the pump dp and flows have been constant (considering instrument and instrument reading inaccuracies) since 1997. No ST has exceeded its upper or lower IST limits. The Quarterly STs provide evidence that the 21 and 22 AF .pumps are not degraded.. The ability of the AF pumps to achieve required flow downstream of the buried piping section at a consistent pump dp provides assurance that the buried piping system condition has not changed. The test also confirms the code requirement that flow is not impaired.

Salem Unit 1 piping is out of service, is being replaced, and will be subject to Code required pressure testing prior to being placed in service.

AFW System TS 3.7.1.2 requires that the AFW system flow paths shall be operable. TS 4.0.5 requires ASME Class 1, 2 and 3 components t.o be tested in accordance with ASME XI. Since the ASME test was apparently missed, we should treat this as a missed TS surveillance of the buried pipe flow path. TS Surveillance Requirement 4.0.3 states that if the surveillance is not performed within its specified frequency ('in this case two (2) cycles), a delay of up to the limit of the specified frequency is allowed IF a risk evaluation is performed for the delay 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 is managed.

- 2 -

REQUIREMENTS IMPACTED:

ER-AA-330-001, Section XI pressure Testing OU-AA-335-015, VT-2 Visual Examination ADVERSE PHYSICAL CONDITIONS:

No adverse physical condition.

WHO WAS NOTIFIED.:

Engineering Director KNOWLEDGEABLE INDIVIDUALS:

Tim Giles, Ed Maloney, Tom Roberts, H. Berrick, E. Villar REPEAT OR SIMILAR CONDITION:

No IMMEDIATE ACTIONS AND RECOMMENDED ACTIONS:

Engineering to provide risk assessment for Unit 2 Auxiliary Feedwater buried pipe to allow delay in test until next refueling outage (2R18).

The risk impact associated with this evaluation shall be managed.

Perform required In-service Pressure Testing in next outage on unit 2 (2R18). Buried piping on unit l will be tested prior to returning to service during current 1R20 refueling outage.

Revise Ul & U2 Salem In-service Inspection Program Long Term Plans to identify all buried Section XI piping systems and required testing.

Review Hope Creek Section XI Pressure Testing Program for similar conditions.