ML17083B110

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)

See also: IR 05000311/2016002

Text

A. Vitale

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION I

2100 RENAISSANCE BLVD.

KING OF PRUSSIA, PA 19406-2713

March 27, 2017

EA-16-244

Mr. Peter Sena, III

President and Chief Nuclear Officer

PSEG Nuclear LLC - N09

P.O. Box 236

Hancocks Bridge, NJ 08038

SUBJECT: WITHDRAWAL OF NON-CITED VIOLATION 05000311/2016002-02

Dear Mr. Sena:

In your letter dated October 24, 2016 (ML16298A161 1), 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described in the inspection report, and requested that the violation be withdrawn.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.

P. Sena 2

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

P. Sena 3

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

Non-Sensitive Publicly Available

SUNSI Review

Sensitive Non-Publicly Available

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