ML18096A191
| ML18096A191 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 05/28/1991 |
| From: | Hehl C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Varga S Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML18096A192 | List: |
| References | |
| NUDOCS 9108090089 | |
| Download: ML18096A191 (3) | |
See also: IR 05000272/1990022
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MEMORANDUM FOR:
FROM:
SUBJECT:
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
475 ALLENDALE ROAD
KING OF PRUSSIA, PENNSYLVANIA 19406
MP'( " " 1991
(..J
"..)
Steven Varga, Director of Reactor Projects - I/II
Office of Nuclear Regulation
Charles W. Hehl, Director,
Division of Reactor Projects
Region I
PROPOSED TASK INTERFACE AGREEMENT REGARDING
THE APPLICATION OF 10 CFR 50.59 RELATIVE TO
UNREVIEWED SAFETY QUESTION (USQ) DETERMINATION,
RE: SALEM NUCLEAR GENERATION STATION
During a routine resident safety inspection (50-272/90-22; 50-311/90-22, attached) conducted
between August 16 and October 1, 1990, the inspectors evaluated Unresolved Item No. 50-272
and 311/90-81-23 (possible misapplication of 10 CFR 50.59), an item that was identified in a
previous IPAT inspection conducted May 14-29, 1990. In the latter inspection, NRC determined
(among other items) that the Licensee failed to perform an evaluation relative to 10 CFR 50.59
pertaining to the non-code repair of corrosion in a containment fan cooling unit (CFCU No. 23).
In this instance, Beliona "R" metal, an epoxy-based surface sealant, was used to repair pits of
corrosion on the tube sheet on the service water side of the motor cooler, but a written safety
evaluation to provide the bases for the determination that an unresolved safety question (USQ)
was not involved, was not documented as required by 10 CFR 50.59.
While the violation was cited in a letter to the Licensee dated November 1, 1990, the staff did
not require the Licensee to respond, since it was believed that PSE&G had recognized the
deficiency and had already established acceptable corrective actions.
However, in a later
management meeting with the Licensee on December 4, 1990, this particular matter was again
reviewed by the NRC in an effort to better understand the Licensee's position and policy relative
to the disposition and resolution of USQ matters. At the meeting the licensee described broad
50.59 evaluation program improvements, but indicated that, even under the new program, no
written safety evaluation would be required for the above-mentioned Belzona repair. As a result
of that discussion, the NRC staff requested that the Licensee formally respond to the originally
cited violation.
Accordingly, the Licensee responded to the NRC in correspondence dated February 1, 1991
(attached), and denied the violation. Region I acknowledged the Licensee's response in a letter
dated March 1, 1991 (attached).
The Licensee asserted that their application of a "screening test" to determine whether the activity
(repair of the CFCU) constituted a change to the facility, was in conformance with the screening
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methodology specified in NSAC-125, "Guidelines for 10 CFR 50.59 Safety Evaluations".
PSE&G indicated that the NRC had previously allowed that licensees should be able to use a
screening test for determining whether a USQ determination was required.
The Licensee took particular exception to our example involving the NO. 23 CFCU, indicating
that the application of their procedure DE-AP.ZZ-008(Q) satisfied the requirements of 10 CFR
50.59. The Licensee contended that the application of the procedure led PSE&G to correctly
conclude that the use of Belzona "R" metal for repair of the CFCU was so benign as to not need
a USQ determination for this change, i.e., the repair would not change the facility as described
in the Safety Analysis Report. As a bases, the Licensee noted that while the tube sheet was
pitted, the pitting was not below the minimum wall thickness, and the unit could have been
returned to service with no further action. However, in an effort to retard further corrosion,
Belzona "R
11 metal was applied to build up the pitted areas to the original thickness and a
bitumastic coal tar coating was applied to protect the tube sheet surface from further corrosion.
The Licensee acknowledged that there may be some question as to whether all of the
requirements of DE-AP.ZZ-008(Q) were satisfactorily met relative to the documentation of the
change, i.e., heat transfer calculations were not reviewed to determined if the tube sheet was
considered as a heat transfer surface (it is not); and the approval of the Belzona "R" material was
poorly referenced (though it was later determined that engineering evaluations were available to
support material and chemical compatibility, and non-adverse system interaction). Consequently,
the Licensee provided enhanced guidance to their review staff to better assure that personnel
understood the application and documentation.requirements relative to change evaluations.
However, PSE&G noted that the documentation deficienCies were not the focus of NRC
concerns, but rather the application of a screening test to determine whether such a modification
constitutes a change to the facility as described in the Safety Analysis Report. In its February
1, 1991, response the Licensee indicated that their current procedure for 10 CFR 50.59 Safety
Evaluation, NC.NA-AP-ZZ-0059(Q) [an upgraded version of DE-AP.ZZ-0008 (Q)], continues
to fully incorporate the guidance specified in NSAC-125, and continues to include a screening
process to decide if proposed modifications actually constitute a change to the facility, and
therefore whether USQ determination is required. PSE&G c.ontends that the application of this
procedure produces a reasonable and systematic approach _to the decision of whether a
modification constitutes a change, such that if a negative finding is made, a USQ determination
is not required.
It is our belief that the Licensee's use of a
11 screening test", if sufficient! y documented to support
that certain types of repair do not constitute an actual change to the facility, is a reasonable
approach for these type of matters. However, in preparing to withdraw this particular violation,
we are concerned that the screening process of NSAC-125 does not result in a detailed safety
evaluation for the subject case, wherein Belzona "R" metal and bitumastic tar (compounds
susceptible to flaking free, clogging heat transfer tubes, or otherwise fouling the system) were
introduced into the system as part of a repair. Further, we recognize a need for more.discreet
guidance relative to the application of "screening tests", and the degree to which NSAC-125
should be acknowledged relative to fidelity with the specifications of 10 CFR 50.59.
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By this letter we propose that a Task Interface Agreement (TIA) be established and request NRR
to: (1) review the Licensee's basis for denial of the violation and advise Region I of concurrence
in withdrawing the item, or provide a basis why the item should remain as cited; and (2),
provide policy or guidance, to be used by all Regions, relative to licensees' application of
NSAC-125, particularly as it pertains to the provision of a "screening test" to determine if the
matter under review requires a written safety evaluation to provide the bases that the change does
not involve an unresolved safety question.
The technical contact for this matter is John R. White, Chief, Reactor Projects Section 2A (FTS
346-5114). This TIA has been discussed with Jame&::Zer.
Enclosures: As Stated
cc:
J. Wiggins, RI
A. Blough, RI
T. Johnson, RI
E. Greenman, NRR
W. Butler, NRR
J. Stone, NRR
Charles W. Hehl, Director
Division of Reactor Projects
Region I