ML18096A893

Responds to NRC Re Deviations Noted in Insp Rept 50-272/92-08.Corrective Actions:Documents Issued Identifying FW Design Pressure & FW Maximum Working Pressure to Be Used to Calculate Required Minimum Pipe Wall Thickness

ML18096A893
Person / Time
Site:	Salem
Issue date:	08/14/1992
From:	Labruna S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLR-N92119, NUDOCS 9208200255
Download: ML18096A893 (8)

Text

Public Service Electric and Gas

• Company Stanley LaBruna Public Service Ele,ctric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200 Vice President - Nuclear Operations AUG 14 1992 NLR-N92119 United States Nuclear Regulatory Commission ATTN: Document Control* Desk Washington, DC 20555 Gentlemen:

REPLY TO ~OTICE OF DEVIATION INSPECTION REPORT NO. 50-272/92-08 SALEM GENERATING STATION UNIT NO. 1 DOCKET NO. 50-272 Public Service Electric and Gas Company (PSE&G) *is in receipt of your letter, dated July a, 1992,.which transmitted a Notice of Deviation associated with the Salem Erosion/Corrosion monitoring program.

This letter was received by PSE&G on July 15, 1992.

In accordance with the directions provided in your letter, our response to this Notice of Deviation is provided in Attachment 1.

Attachment

• 9200200255 920814 PDR-ADOCK 0500~B~2 G

Sincerely,

,,jeDI 1

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Document control Desk

~NLR~N92119 2

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.Mr. T. T. Martin, Administrator - Region I

u.. s ~ Nuclear Regulatory Commission 4 7 5 All.endale Road King of Prussia, PA.19406.

Mr. J. stone, Licensing Project Manager

. U,. S. Nuclear Regulatory Commission.

One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr.

T~ P. Johnson (SOS)

USNRC Senior.Resident Inspector Mr. K. Tosch, Chief NJ Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Enginee~ing CN 415 Trenton, NJ 08625 AUG 14 1992

ATTACHMENT 1 REPLY TO NOTICE OF DEVIATION INSPECTION REPORT NO. 50-272/92-08 SALEM GENERATING STATION UNIT NO. 1 DOCKET NO. 50-272

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• NLR-N92119 I.

INTRODUCTION NRC Inspector Mr. P. Patnaik conducted an inspection at the Salem Unit 1 Generating Station from May 26 through 29, 1992*

Included in this inspection was a review of the Salem Erosion/Corrosion (E/C) monitoring program.

The inspector reviewed the components selected for ultrasonic (UT) pipe thickness measurement, UT data results,. PSE&G' s*- analysis of the data and disposition of the components.

The inspector noted that 52 components had been selected for UT measurement.

PSE&G's analysis of the UT results identified 11 f eedwater pipe components outside containment that were below the design minimum wall thickness.

The design minimum wall thickness was calculated using the feedwater pipe design basis code ANSI B31.1 (1967 Ed~)*

PSE&G calculated the minimum pipe wall.

thickness using the feedwater normal operating pressure instead of the feedwater maximum design pressure.

This is not in accordance with ANSI B31.1 (1967 Ed.).

As a result, a Notice of Deviation was issued.

This Notice of Deviation is responded to below.

Prior to the issuance of this deviation, PSE&G personnel met with the NRC staff in Rockville, Md. on June 25 and July 1, 1992 to discuss the Salem Erosion/Corrosion monitoring program. -Meeting minutes for both meetings were issued by' the NRC in two Salem docket letters, both dated July 10, 1992.

During these meetings PSE&G described corrective actions and program enhancements which are applicable to this Notice of Deviation.

Consequently, this response reiterates* those commitments and does not contain any new commitments.

II.

REPLY TO NOTICE OF DEVIATION A.

Notice of Deviation "The Salem Updated Final Safety Analysis (UFSAR) Section 10.4.7.1 states that the feedwater piping outside the containment is designed to ANSI B31.1 (1967 Ed.) Code.

ANSI B31.1 requires that power piping systems be designed for the most severe condition of coincident pressure and loading.

For portions of the feedwater system, the normal operating pressure is 1150(*) psig, but the feedwater pump maximum design output pressure is 1870(*) psig.

Contrary to the above, the NRC review of licencee's disposition of degraded components in the feedwater system outside the containment, e.g., expanders, elbows, pipe bends, etc., that were below minimum design wall due to manufacturing error and PAGE 1 OF 5

~*-

NLR-N92119 erosion/corrosion, indicated licensee's acceptance based on operating pressure alone and thus violated the applicable design Code ANSI B31.l (1967) specified in the UFSAR."

.* Please note that.in the July 1, 1992 PSEG/NRC meeting, these pressures were identified as 1195 and*1893 psig respectively.

See NRC meeting minutes in letter to PSE&G dated July 10, 1992; PSE&G does not dispute this Notice of Deviation. *

.B.

Reason.for Deviation As stated in the June 25, 1992 PSE&G/NRC management meeting, PSE&G identified the following reasons for*the deviation:

(i)

Procedural*deficiencies. *The Salem E/C Program was not adequately described and controlled by procedures.

(2)

Eval.uation errors.

Engineering personnel did not use the correct pressure to evaluate rec;iuired minimum wall thickness. *

(3)

Insufficient programmatic oversight.

C.

Corrective Steps Taken and Results Achieved The corrective actions described below have been taken to address th.e Notice of Deviation.

These corrective actions were previously described during the June 25 and July 1, 1992 PSE&G/NRC management meetings.

They are repeated here along with a description of the results achieved.

(1)

Procedural deficiencies.

have been taken:

The following corrective actions (a)

PSE&G has issued documents identifying the feedwater design pressure and f eedwater maximum working pressure to be used to calculate the required minimum pipe wall thickness.

These pressures were identified in accordance with.ANSI B31.l (1967 Ed.).

These pressures and the minimum feedwater pipe wall calculation methodology were discussed in detail with NRC personnel on July 1, 1992 and determined to be acceptable-.

For information see Enclosure 1 to the NRC letter to PSE&G dated July 10, 1992.

The result achieved is that documented direction has been provided to ensure that engineering personnel use the correct feedwater design pressure or*maximum PAGE,2 OF 5

~-* I*

NLR-N92119 working pressure to calculate the minimum f eedwater pipe wall thickness in accordance with ANSI B31.1 (1967 Ed.)..

(b)

PSE&G has issued a methodology for conservatively calculating the E/C rate and the predicted minimum wall thickness to the next refueling outage.

This methodology was discussed in detail during the July 1, 1992 PSE&G/NRC meeting and determined to be acceptable.

The result achieved is that a controlled methodology exists to ensure engineering personnel consistently and conservatively calculate the predicted minimum pipe wall thickness to the next refueling outage.

This provides assurance that components reviewed under the E/C program will be dispositioned correctly.

(2)

Evaluation errors.

The following corrective actions have been taken:

(a)

Engineering personnel that perform and review E/C calculations have been counseled and made aware of the requirement to use design pressure or maximum working pressure when performing minimum pipe wall thickness calculations.

This is in in accordance with ANSI B31.1 (1967).

The result achieved is that engineering personnel that perform and review E/C calculations are explicitly aware of the requirement to use design pressure or maximum working pressure when calculating minimum pipe wall thickness in accordance with ANSI B31.1 (1967).

(3)

Insufficient programmatic oversight.

(a)

PSE&G management has recognized the need for a governing document that clearly identifies program expectations, responsibilities, technical requirements, documentation requirements and independent review requirements fo_r E/C monitoring activities.

In the interim, managment has issued technical direction and taken corrective actions to ensure that E/C program issues identified during recent PSE&G/NRC management meetings have been addressed.

The result achieved is that the necessary governing procedure is being developed to ensure long term implementation of an E/C monitoring program that meets PSE&G and industry standards.

PAGE 3 OF 5

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NLR-N92119 D.

Corrective Steps to be Taken to Avoid Further Deviations.

The corrective actions described below will be taken to prevent recurrence of the condition described in the. Notice of Deviation.

These corrective actions were previously described during the June 25 and July 1, 1992 PSE&G/NRC management.meetings.

(1)

Procedural deficiencies.

The following future corrective actions will be taken:

(a)

An E/C programmatic standard will be developed and issued by September JO, 1992 describing the requirements, responsibilities and content of the PSE&G E/C monitoring program.

Associated implementing procedures will also be issued by September JO, 1992.

(b)

PSE&G will have a third party conduct a final review of the PSE&G E/C program after the programmatic standard has been issued.

This will be completed by December Jl, 1992.

(c)

PSE&G will also request that the Electric Power Research Institute (EPRI) conduct a review of the PSE&G E/C monitoring program after the E/C Programmatic standard has been developed and issued.

This review will be.completed by December Jl, 1992.

(2)

Evaluation errors.

The following future corrective actions will be taken:

(a)

PSE&G personnel will be trained in the use and requirements of the E/C programmatic standard and implementing procedure(s) by the next Salem refueling outage, currently scheduled for March 199J.

The E/C programmatic standard and implementing procedures will provide guidance in the evaluation and disposition of pipe components.

(J)

Insufficient programmatic oversight.

(a)

As indicated by the corrective actions enumerated here and in previous PSE&G/NRC meetings, PSE&G management has directed increased programmatic oversight to the PSE&G E/C monitoring program.

This programmatic oversight will be institutionalized in the PSE&G E/C programmatic standard.

PAGE 4 OF 5

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NLR-N92119 E.

Date When Corrective Steps Will be Completed The future corrective actions taken to avoid this deviation in the future will be completed with the issuance and implementation of the PSE&G E/C programmatic standard.

This is scheduled to be completed by the next Salem refueling outage, *currently planned in March 1993.

The final third party review and the EPRI review will independently confirm the adequacy of the E/C programmatic standard and its implementation.

The third party review and the EPRI review will be completed by December 31, 1992

• PAGE 5 OF 5