ML20115E162
| ML20115E162 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 04/08/1985 |
| From: | Martin T Public Service Enterprise Group |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8504190214 | |
| Download: ML20115E162 (3) | |
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w Public Service Electric and Gas Company Thomas J. Martin 80 Park Plaza, Newark, NJ 07101 201430-831E Mailing Address: P.O. Box 570, Newark, NJ 07101 Vice President Engineering and Construction April 8, 1985' Dr. Thomas E. Murley, Administrator U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Reg' ion I 631 Park Avenue King of Prussia, Pennsylvania 19406
Dear Dr. Murley:
NRC INSPECTION _ REPORT #85-01 NOTICE OF VIOLATION HOPE CREEK GENERATING STATION Your letter dated March 7, 1985, transmitted the above referenced Inspection Report which contained a Notice of Violation citing one (1) item of noncompliance concerning the presence of water in one Emergency Diesel Generator heat exchanger.
The following response is provided in accordance with the Notice of Violation.
As of January 9, 1985, the Emergency Diesel Generator jacket water heat exchanger AE-405 was found with seven (7) inches of static water level on the tube side; the last two (2) tube rows were submerged.
Corrective Steps Taken and Results Achieved As detailed in the Notice of Violation, storage and maintenance procedures did not include specific requirements to perform periodic inspection of the internals of the Diesel Generator jacket water heat exchangers.
Bechtel's construction procedure SWP/P-15 does howevar, require an evaluation to determine the need for revised maintenance requirements when equipment is permanently installed.
For the subject heat exchanger, this evaluation was performed by Field Engineering by reviewing the manufacturer's storage and maintenance recommendations, which did not indicate any need for periodic internals inspection.
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Dr.
T.
E. Murley 2
4/8/85 An investigation was initiated to identify the source of the water and to determine whether the performance of the heat exchanger would have been degraded as a result.
It was found that demineralized water leaked through an isolation valve into the heat exchanger'during the performance of a piping hydrotest on December 12, 1984.. Visual inspection of the heat exchanger internals on January 16, 1985, by Bechtel Field Engineering and a Colt Industries representative determined that the light surface corrosion and accumulated deposits found had not' degraded the integrity of the heat exchanger.
As stated in their report,
"...the rust contamination is surface type rust and deposits of piping surface rust.
This condition does not affect the condition or intended performance of this heat exchanger."
In order to assure the adequacy of the existing program, Colt Industries was specifically questioned as to the need for periodic inspection of the heat exchanger internals.
They have reaffirmed that no such periodic inspections are necessary.
It was noted that the subject Notice of Violation refers to ANSI N45.2.2, paragraph 3.2.4 (1) which addresses packaging.
Prior to shipment to the jobsite, the heat exchangers were drained and blown dry in accordance with Colt Industries
_ procedures.
As detailed above, it has been determined that the existing program meets the intent of ANSI N45.2.2, paragraph 1.2 of which states, in part, "The requirements are intended to assure that the quality of items is not degraded as a result of packaging, shipping, receiving, storage, and handling practices
.and techniques."
Corrective Steps Taken To Preclude Recurrence A review of the program for maintenance of heat exchangers after installation was undertaken in June 1984 when it was recognized that storage requirements may not be applicable once a component is installed.
As a result of this review, it was determined that stainless steel tubed heat exchangers would receive either a dry air purge with dessicant or nitrogen purge where access is restricted for dessicant placement.
As part of this review, it was determined that special layup procedures were not required for non-stainless steel heat exchangers.
This determination was made by reviewing vendor instruction manuals and/or contacting the appropriate vendors.
.G-s ;
Dr. T. E. Murley 3
4/8/85 The Date of Full Compliance Implementation of the layup program for stainless steel heat exchangers is in process with full implementation scheduled for June 21,~1985.
Very truly yours,
/
C Office of Inspection and Enforcement Division of Reactor Construction Inspection Washington, D. C.
20555 NRC Resident Inspector P.
O. Box 241 Hancocks Bridge, NJ 08038 b
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