ML102990173

Email from Lew, David to Conte, Richard, Et Al, Summary of 4/27/10 Internal NRC Call on Salem Unit 2 AFW Piping.

ML102990173
Person / Time
Site:	Salem
Issue date:	04/28/2010
From:	David Lew Division Reactor Projects I
To:	Arthur Burritt, Leonard Cline, Conte R NRC Region 1
References
FOIA/PA-2010-0334
Download: ML102990173 (2)

Text

Ziev, Tracey From: Lew, David Sent: Wednesday, April28, 2010,7:40 AM To: Conte, Richard; Burritt, Arthur; Cline, Leonard; Schroeder, Daniel; Balian, Harry; OHara, Timothy; Schmidt, Wayne; Cahill, Christopher Cc: Clifford, James; Roberts, Darrell

Subject:

Re: Summary of 4/27/10 Internal NRC Call on Salem Unit 2 AFW Piping Rich, Please confirm that AFW is Class 3 and not 2. Thanks. Dave From: Conte, Richard /it4 To: Ennis, Rick; Burritt, Arthur; Cline, Leorfard; Schroeder, Daniel; Balian, Harry; OHara, Timothy; Lupold, Timothy; Tsao, John; Manoly, Kamal; Schulten, Carl; Elliott, Robert; Chernoff, Harold; Nelson, Robert; Gitter, Joseph; Howe, Allen; Honcharik, Michelle; Bowman, Eric; Miller, Barry; Schmidt, Wayne; Cahill, Christopher Cc: Lew, David; Clifford, James; Roberts, Darrell Sent: Wed Apr 28 07:31:46 2010

Subject:

RE: Summary of 4/27/10 Internal NRC Call on Salem Unit 2 AFW Piping nice summary Rick.

only comment is I believe the licensee is doing an operability on AFW - they haven't been told about the apparently wrong path they are on related to none use of TS 4.0.3 and need to go into the strutural integrity LCO.

expanding distibution to my management - Darrell was particularly interested in summarizing/documenting decision yesterday, very nice summary.

we are thinking of memorizing in a TIA, like Pilgrim, we also need to think generic implications your email is a good discussion point for todays conference.

From: Ennis, Rick Sent: Wednesday, April 28, 2010 7:19 AM To: Burritt, Arthur; Cline, Leonard; Schroeder, Daniel; Balian, Harry; Conte, Richard; OHara, Timothy; Lupold, Timothy; Tsao, John; Manoly, Kamal; Schulten, Carl; Elliott, Robert; Chernoff, Harold; Nelson, Robert; Giitter, Joseph; Howe, Allen; Honcharik, Michelle; Bowman, Eric; Miller, Barry; Schmidt, Wayne; Cahill, Christopher

Subject:

Summary of 4/27/10 Internal NRC Call on Salem Unit 2 AFW Piping The following is a summary of the internal NRC call held on 4/27/10 to discuss issues associated with the Salem Unit 2 AFW piping. These issues were raised following licensee discovery of degradation of the Salem Unit 1 AFW buried piping and the subsequent extent of condition review.

1) The licensee has never performed the pressure testing required by paragraph IWA-5244 of Section XI of the ASME Code for the buried AFW piping. Technical Specification (TS) Surveillance Requirement (SR) 4.0.5 provides requirements regarding inservice inspection and inservice testing of ASME Code Class 1, 2, and 3 components. SR 4.0.5.d states that "[p]erformance of the above inservice inspection and testing activities shall be in addition to other specified Surveillance Requirements." Therefore, the testing required by IWA-5244 is considered a TS surveillance requirement.

2) SR 4.0.3 allows a delay in the performance of a SR when it is discovered that a surveillance was not performed within its specified frequency (i.e., missed surveillance). PSEG is currently invoking the provisions of SR 4.0.3 to justify not performing the IWA-5244 testing for the AFW piping until the next outage.

3) A Pilgrim TIA dated 1/23/09 (ML083660174) states that "the NRC staff's position is that a missed SR is different than an SR that was never performed." Some of the key points in the TIA supporting this position are as follows:

a) Use of the word "frequency" [in SR 4.0.3] establishes an interval, a period of time, that includes an initial performance of the SR, and a specified time period to re-perform the SR thereafter, i.e., to repeat the surveillance.

b) SRs are performed at frequencies that are more often than the mean-time to failure of particular systems. Thus, most SRs confirm that SSCs are operable given an operable finding at the previous testing interval.

Based on the TIA, PSEG's use of SR 4.0.3 to justify a delay in performing a surveillance that never has been performed is contrary to the NRC staff's current interpretation on use of SR 4.0.3.

4) SR 4.0.1 states, in part, that "[f]ailure to perform a Surveillance within the specified frequency shall be failure to meet the Limiting Condition for Operation, except as provided in Specification 4.0.3. Since SR 4.0.3 is not applicable to surveillances that have never been performed, Salem Unit 2 does not meet LCO 3.4.11.1 which states "[t]he structural integrity of ASME Code Class 1, 2 and 3 components shall be maintained in accordance with Specification 4.4.11.1." Note, SR 4.4.11.1 references SR 4.0.5 as the surveillances required to demonstrate structural integrity of the ASME Code Class 1, 2 and 3 components. The AFW piping is Code Class 3. Action c in LCO 3.4.11.1 states that:

With the structural integrity of any ASME Code Class 3 component(s) not conforming to the above requirements, restore the structural integrity of the affected component(s) to within its limit or isolate the affected component(s) from service.

The above Action Statement has no time limit.

5) The licensee is currently evaluating the structural integrity of the Salem Unit 2 AFW buried piping. If the licensee concludes that the structural integrity is acceptable, then Salem Unit 2 would no longer be in Action c of LCO 3.4.11.1 (i.e., structural integrity would be restored in accordance with Action c). If the licensee concludes that the structural integrity is not acceptable, they would need to isolate the affected components from service in accordance with Action c. Isolation of the affected AFW piping would put them in the Action b in LCO 3.7.1.2 for two inoperable AFW pumps. [Region I, please confirm number of AFW trains that would be inoperable] This would result in a plant shutdown.

6) Failure to perform the testing required by IWA-5244 is a violation of ASME XI. The licensee would not need to submit a relief request if they are planning to do the test the next outage.

7) The licensee believes that the Salem Unit 2 AFW buried piping is in better condition that the Unit 1 piping. Region I will continue to review the licensee's efforts on these issues. The NRC staff is not aware of any information at this point indicating a lack of structural integrity for the Salem Unit 2 AFW buried piping.

Please let me know if you have any corrections or clarifications needs to the above summary.

Thanks, Rick 2