ML18095A835
| ML18095A835 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 04/01/1991 |
| From: | Russell W Office of Nuclear Reactor Regulation |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML18095A837 | List: |
| References | |
| GL-90-05, GL-90-5, NUDOCS 9104050230 | |
| Download: ML18095A835 (4) | |
Text
,,.*
l c..,,.~ 111041~
!~~\\
\\~.)
UNIT!D 8TATH NUCLEAR REQULAiORV COMMISSION WASHINGTON, D. C. 20111
-APR 11991 MEMORANOUK FOR:
Thomas T. Mart1n Regional Adm1n1str1tor Region I FR<lil:
SUBJECT:
W111fam T. Russell *.Associate Director for Inspection I Technical Assessment Office of Nuclear Reactor Regulation REPORTABILITY OF ASME CODE CLASS III DEFECTS On January 4, 1991, Public Service Electric and G&s Company, the 11censee for Salem 1 and 2, "*t with the stiff to d1scuss replacament of th1 plant's service water system.
The licensee and the staff discussed the need for replacement,-the scope and status of replacement.* and d1s1gn changes to improve the raliab111ty of the system.
Durf ng the d1scussfan, the l1cens1e stated that the NRC 1 s staff had asked that they notify NRC's Emergency Operations Center of aach occurrence of through wall leakage fn the servfc1 water system under 10 CFR 50.72(b)(1)(11)
(B). This section of th.a CFR requires that tha EmtrgtnC1 Operations Cer1ter be notifidd w1th1n one hour of occurrence of a cond1tton that 1s outs1da the*
design basfs of the plant. The 11censae requested that the staff review the need for the licensee to make these notif1cat1ons.
The staff agreed to do so. This memorandum summarizes the resulti of that revf dw.
Operat1ng licenses for Units 1 and 2 at the Salem plant were issued on December 1. 1976. and May 20, 1981, respect1va1y.
From early operation of the plant unt11 present. numerous leaks through the walls of piping 1n the service water system have occurred as a result of the qua11ty of the water and the piping in the service water system. Tha system uses water from the OMlaware River which conta;ns chlorides 1n various concentrat1ons, micro and macro biological organisms, industrial pollutants. and silt. Thi system was fabrf c1t1d from carbon steel piping that had been co4ted on the 1~terior surface w1th cement.
In 1987, the licens11 1n1t1ated 4 p14nn1ng effort to improve the service water system. This effort resulted 1n a plan to replace the piping, valves.
and heat exchangers-or heat exchanger tubes with new components fabricated from sta1n1eas sttttl and other materials that are bett~r able to withstand the service cand1tfons.
The pl4n was implemented, and the syst~ 1s being replactd in segment* during refueling outages. However, frequent through wall leaks continue to occur fn thusa segments of the system that have not been replaced. These events are expected to continue unt11 replaeument of the sy5t~m 15 completed 1n 1994.
At present. the work in the nuclear area of CONTACTS:
Robert A. Hermann, EMCB 492-0768 Roger w. Woodruff. OEAB 492-1152 9 ) 0 LJ 0 ') 0 2 3 0.><A
.e Thomas T. Martin
- 2 -
the p1411t 1s 43S complete *. The total cost of the project will be 1n excess of 100 mi111on dollars.
Other licensees for plants using salt, brack1sh, or*fresh service water are also experiencing problems wfth the pfp1ng material 1n thefr servfc1 water systems. During a recent 12 month period, the Emergency Operations Center was notified of 26 service water leaks. Of this number, 22 of the leaks occurred at Sal&m. This d1sproport1unate number of riotf f1ca.t1ons from Salem is fndfcatfve of problems fn 1nterpret1ng 10 CFR 50.72. It fs apparent that either the licensee for Salem fs over reporting or other licensees ire under reporting sarvice water problems.
Notf ffcatfons from Salem have involved leak rates as small as several drops par minute.
In these instances, leakage has not rendered the ~arvfce w1ter system fnoperable according to tha definition of oparab111ty in Teehnf cal Specification 1.18 for Salem 1, and the licensee has not notified the Emergency Operations Center that the system has been tnoperabl*. Rather, the licansae has nat1f1ed the Operations Center that th* pl&nt waa in a canditfon that is outside the design basts.
The tanu Mdes1gn basesu is defined in 10 CFR so.2.
In essence, t"'t section of the CFR defines "design basasu as the information that 1dent1f1es the sp.eciffc functions to be perfonned b¥ the system and th* spec1f1c values of parameters that bound the design where th* values are derived from accepted design pract1ces or accident analyses.
The Salem service watar p1p1ng was designed to meet ANSI Standard 831.7.
However, -the system was re-classified for 1nserv1ce inspection purposes using Regulatory Guide (RG) 1.2~. RG 1.26 describes a quality classification system ralated to spec1f1c national standards that may be used to determine qua11ty standards acceptable to the NRC staff. Regulatory Pas1t1on 2.b and Table 1 fn RG 1.28 1nd1cate that service water systems should be trd&ted u ASME Boiler and Pressure Vessel Code,Section III, Class 3 systems.
On February 12, 1976, 10 CFR 50.55a(g) was ravisMd to require that licensees for pow1r reactors w1th construction penn1ts issued before J4nuary 1, 1971.
meet those requirements of th* ASME Bo11er and Pressure Vessel Cede.
Section XI, to the extent pr~ctical. which apply to 1nserv1ce examination and repair of flaws. Construction parmfts for Salem 1 and 2 were issued on September *25. 1968, and the 11censee must comply with 10 CFR 50.55a(g).
Section XI of the ASME Code does not require periodic volumeter1e exam1nit1on of ASME Code Class 3 piping. It does require v1sua1 inspection of p1p1ng for defects, 1nc1uding through wall flaws as indicated.by 1eak1ng fluid. Sact1on XI, Paragraph IWA 5250, "Corrective Actions," requires repa1r in accordance with IWA-4000 or rep1aceruent in accordance with IWA-7000 of piping to eliminate le~ks when they occur. Generic Lettar 90*05 frcm NRR to 1f c:ensus and memoranda from 01v1s1on of Engineering Technology to the regional Reactor
I *-f' Thomas Safety Dfvisfons and to NRR 11 Director, D1v1s1on of R~actor Projects dated August 16 and September 6, 1990. raspect1vely, describe the procedure for obta1nfng relief from the Code to allow temporary non-coda repairs by 11cen-seas, the k1ncts of temporary non-code repairs that are acceptable to NRC. and the length of t1me that such r~pa1rs may remain in service.
Whan leakage occurs, the service water system does not satisfy Section XI of the ASHE Code. The licensee must then avaluat~ the system 1n a timely manner in accordance with Generic Letter 90*05 ta d1t1rm1ne 1f the system hes the structural capability ta reliably perform its intended funct1on. If the 11c1nse1 1s operating the unit at power when th~ flaw 1s discovered, d1t1rmin1s that structual cdpab111ty fs maintained according to the generic letter flaw evaluation cr1terta, requests relief from Section XI of the ASME Code as permf tted by the generic l~tter, and rec~1vas staff approval~ the licensee may continue to operate-it power and make tempor4ry repairs fn accordance with the guidance provf ded 1n the generic letter.
If the degraded piping does not meet the flaw evaluation ct1ter1a of the generic latter or the cr1terfa of the design code or standard for the ptpfng..
system or the license* does not make a pennanent Code repair to restore structural 1ntegr1ty w1th1n the tfme allowed by the Technieal Spectftcatfons, then the licensee must nQtffy the Emergency Operations Center as required by lf CFR 50.72(b)(l)(1i)(B), and th¥ regions should enforce thest requirements_. If the licensee for Salem was ccmply1ng with Generic Letter 90-05 including NRC approval and th~ p1ping was 1n conformance w1th ANSI Standard 831.7, then t~e pl4nt was not f n a condition that was outside of tts design basis and nct1ffeat1on of the Emergency Operations Center of through wall leakage was no required under 10 CFR 50.72(b)(l){11)(B).
On occasion, the licensee for Salem has isolated a leaking section of service water piping to make 1 permanent code repair. In this situation. the 1 icensee has entered the action statement of the 11mit1ng condi t1an for oparat1on (LCO) set forth 1n Salem*s Technical Spec1f1cat1on 3.7.4. This LCO requires that at least two fndependent serv1ca water loops shall be operable.
However, not1f1cat1on of these events under 10 CFR 50.72(b)(2)(111) is not required as 1ong ts the action statement in the LCO is not violated. Thia rule requires notfffcation of the Emergency Operations Cente~ within four hours of an event that alone ca~ld have prev~nted fulf111ment of the safety function of systems needed to maintain the reactor in a safe shutdown condition.
In sunrnary, licensees need not notify tha Emergency Op~rat1ons Center of through w~ll 1eaks fn service water systems unless they are not 1n compliance w1th Generic Letter 90*05, the code under which the pipfng was designed, or the action statement 1n the LCO for operab111ty of the system. However.
I Thomas T. Martin
'+ -
licensees may submit, if they wish, voluntary notifications to the Emergency Operations Center.
In those situations where notification of the Emergency Operations Center is required under lb CFR 50.72(b)(l)(ii)(B), a Licensee Ev~nt Report is required also after 30 days under 10 CFR 50.73(a)(2)(ii)(B).
This memorandum is being provided, to £~onz:tion.
cc:
J. G.
1 E.
- v.
A. C.
- c. E.
S. A.
- s. D.
A. B.
R. D.
J. B.
T. M.
Partlow, NRR Richardson, Thadani, NRR Rossi, NRR Varga, NRR Ebneter, RI!
Davis, RIII Martin, RIV Martin, RV Novak, AEOD NRR r william T. Russell, Associate Director for Inspection & Technical Assessment Office of Nuclear Reactor Regulation
...