ML102980470
| ML102980470 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 07/22/2010 |
| From: | O'Hara T Engineering Region 1 Branch 1 |
| To: | Arthur Burritt Reactor Projects Branch 3 |
| References | |
| FOIA/PA-2010-0334, IR-10-003 | |
| Download: ML102980470 (29) | |
See also: IR 05000272/2010003
Text
UNITED STATES NUCLEAR REGULATORY
COMMISSION
REGION I 475 ALLENDALE
ROAD KING OF PRUSSIA, PA 19406-1415
July 22, 2010 n/9 "(1WL-MEMORANDUM
TO: Arthur L. Burritt, Chief Projects Branch 3 Division of Reactor Projects Richard J. Conte, Chief Engineering
Branch I Division of Reactor Safety THRU: FROM: Timothy L. OHara, Reactor Inspector Engineering
Branch 1 Division of Reactor Safety SUBJECT: INSERVICE
INSPECTION
ACTIVITIES
INSPECTION
FEEDER FOR SALEM UNIT 1, INSPECTION
REPORT 05000272/2010003, REVISION OF July 21, 2010 The enclosed feeder contains input for the subject report resulting
from inspection
of Inservice Inspection (ISI) activities
during the period from April 5, 2010 to June 28, 2010, at Salem Unit 1.The inspection
was conducted
using Inspection
Procedure
71111.08, Inservice
Inspection
Activities
and Temporary
Instruction (TI) 2515/172, Reactor Coolant System Dissimilar
Metal Butt Welds. The results of this inspection
were presented
to Mr. Ed Eilola, Salem Plant Manager, at an exit meeting on June 28, 2010.Suggested
Cover Letter Input This feeder documents
one NRC-identified
finding of very low safety significance (Green). This finding was determined
to be a violation
of an NRC requirement.
This feeder also documents
a licensee-identified
violation, which was determined
to be of very low safety significance, in section 40A7 of this report. Because these violations
are of very low safety significance
and because the issues were entered into your corrective
action process, these findings are being treated as non-cited
violations (NCVs) consistent
with Section VI.A.1 of the NRC Enforcement
Policy.Issue of Agency Concern: Buried, Safety Related Piping: Because of an ongoing issue of Agency Concern about the degradation
of buried piping, this issue is being documented
as a licensee-identified
finding in Section 40A7, in accordance
with the guidance of IMC 0612-10."/ ý`bD'_ý'
V **vt' S 2 Nospecific action is needed for this concern in light of industry initiatives
on buried piping and the NRC Buried Piping Action Plan.Since this issue, as noted below, is licensee identified, a long discussion
was not permitted
by IMC0612 format requirements.
Documenting
an issue of agency wide concern appears to only apply to minor findings, however, this issue is more than minor and licensee identified.
The following
finding of very low safety significance
was identified
by PSEG and is a violation
of 10 CFR 50, Appendix B, Criterion
III, Design Control, an NRC requirement.
PSEG did not providean
effective
protective
coating for the buried AFW piping. This issue has been evaluated
via IMC 0609, Attachment
4, Initial Screening
and Characterization
of Findings and IMC 0612, Appendix B, Issue Screening.
During a planned excavation
and inspection
of the Unit 1 AFW buried piping to SG #12 and SG#14, PSEG identified
corrosion (significantly
below minimum wall thickness
for a design pressure of 1950 psi) of the safety related, ASME Class 3, Seismic Class 1 piping. PSEG repaired or replaced the affected Unit 1 buried AFW piping before returning
the plant to operation.
Portions of the Unit 1 and Unit 2 Auxiliary
Feedwater (AFW) System piping is buried piping and has not been visually inspected
since the plant began operation
in 1977 for Unit I and since 1979 for Salem Unit 2. In April 2010, approximately
680 ft. (340 ft. of the #12 SG AFW supply and 340 ft. of the #14 SG AFW supply) of piping between the pump discharge manifold and the connection
to the Main Feedwater
piping to the affected SGs was discovered
to be corroded to below minimum wall thickness
(0.278") for the 1950 psi design pressure of the AFW System. The lowest wall thickness
measured in the affected piping was 0.077".Preliminarily, PSEG representatives
believe that there was an inadvertent
omission of coating during construction
days. PSEG plans on excavating
the Unit 2 buried piping to inspect the condition
during the next Unit 2 outage scheduled
for the spring of 2011. Although no leakage was evident for these conditions, the inspector
questioned
if periodic pressure test had been conducted
on this underground
piping and this resulted in an NRC identified
finding, as noted in this feeder, along with an operability
determination
for Unit 2 and as risk assessment
for waiting to do the above noted inspection.
This analysis resulted in a revised pipe design rating for Unit 2 down to 1275 psig.10 CFR 50, Appendix B, Criterion
11, Design Control, states, in part, "Measures
shall be established
to assure that applicable
regulatory
requirements
and the design basis ... for those structures, systems, and components
to which this appendix applies are correctly translated
into specifications, drawings, procedures, and instructions.
These measures shall include provisions
to assure that appropriate
quality standards
are specified
and included in design documents
and that deviations
from such standards
are controlled.
Measures shall also be established
for the selection
and review for suitability
of application
of materials, parts, equipment, and processes
that are essential
to the safety-related
functions
of the structures, systems and components." r ~~'P w~" ,~ ~*0 '7 3/4
3 Contrary to these requirements, PSEG did not provide engineering
evaluations, vendor certification, or testing data to demonstrate
that the specified
coating would protect the buried AFW piping for the design lifetime of the plant. Also, PSEG did not assure appropriate
quality standards
which assure that deviations
from such standards
were controlled.
Additionally, PSEG did not provide measures for the selection
and review for suitability
of the coating materials
for the buried AFW piping application, for periodic inspections
to ensure that the.applied coating was protecting
the buried AFW piping, and did not provide engineering
details I; demonstrating
the ability of the coating to protect the buried AFW piping for the design life of the , ,.plant.Ad ua This licensee identified
finding affects the mitigating
systems cornerstone
by affecting
the secondary, short term decay heat removal capability.
Because the finding did not result in loss ., of operability
or functionality
the inspector
determined
that the finding was of very low safety significance, Green. The inspector
determined
that this licensee identified
finding is more than minor, and that a Cross Cutting Aspect did not exist because the issue was not indicative
of current performance
because the condition
existed since 1977. Specifically, the section of * , piping under question was identified
with degradation
that put the system outside its originalf, /design basis (1950 psi design rating); and PSEG was required to make significant
revisions
to the system design analysis to take credit for available
margin to show that the system remained -operable.
.: " Because PSEG entered this condition
into the corrective
action process (Notification
20456999)
.: and because the issue is of very low safety significance (Green), this issue is being treated as a .. : ..licensee identified
non-cited
violation
consistent
with Section VI.A. 1 of the NRC Enforcement
the EQ:ACE for the corroded AFW piping, had not ! l >2 completed
the Root Cause Evaluation
for missing the IWA-5244 pressure tests, and had not completed
it's evaluation
of Notification
20462034, it was agreed that an annual PI&R sample would be completed
to review these documents
to determine
that the following
.comments/observations
have been addressed
by PSEG. It is anticipated
that this sample will >be performed
in September
2010 depending
upon PSEG completion
of the cause , determinations
and Notification
actions.The inspector
made other observations
related to the finding on the AFW pressure testing issue .-and degradation
noted in the AFW yard piping. PSEG intends to address the following observations/comments
in the cause determinations
and Notification
evaluations.*, (1) The PSEG buried piping inspection
procedure
did not document how a representative
inspection
sample is selected and did not enumerate
the basis for the inspection
sample I selection(s).
I: (2) The PSEG buried piping inspection
procedure
does not provide a threshold
criteria for .. .inspection
conditions
which must be entered into the corrective
action process for evaluation, potential
resolution
and/or tracking.:"" , ,97, ,-... ..I Y,, .: "a ',: :::" " a ,
4 (3) PSEG has not defined a design life for the new coating on the replaced buried AFW ,*....-6 piping for Unit 1. Also, PSEG has not determined
an excavation
and inspection
frequency
for , 6,6 the newly coated, replaced Unit 1 buried piping.(4) Notification
20459689 reported the failure to perform the ASME, Section Xl, paragraph
," IWA-5244 required pressure tests on the buried AFW piping for Unit 1 and Unit 2. This Notification
states, "The system pressure test boundary drawing ($2-SPT-336-0)
identifies
the piping as YARD piping not buried piping." It is not clear what PSEG is doing to ensure that : 6 : other system drawings which may contain the same YARD markings and are potentially
not being treated as buried piping and components.
- ,, : 4.$: *;;(5) PSEG Buried Piping Program assumes that buried piping is protected
by a coating 666 system to protect the piping from degradation/corrosion
for the design life of the plant. However, the Unit 1 AFW piping was discovered
to not have been coated or protected.
It is not clear what PSEG is doing to confirm or verify that other buried piping is protected
with an effective
coating which will protect the piping for the plant life. : '6i ;6;f: (6) PSEG agreed to provide the ASME, NIS-2 forms with ANI approval for the completion
of the repair/replacement
of the Unit 1 AFW piping. .(7) PSEG has initiated
Notification
20462034 to investigate
and confirm the basis of the )1950 psig design pressure of the AFW system. Actions included in this Notification
were in 66,6 ~progress when the inspection
ended on June 28, 2010. i66 Enclosure:
Feeder for Salem Unit 1, Inspection
Report No. 05000272/2010003, 66 '05000311/2010003 , ,) 4,........ '66664.' i,666 6 6
5 cc w/Enclosure: (VIA E-MAIL)A. Burritt, DRP L. Cline, DRP D. Schroeder, DRP, SRI -Salem Unit 1 T. O'Hara, DRS R. Hardies, NRR DRS Files 4 ~4 '>4~44~ ~~'A~"~ 4~.SUNSI Review Complete:
TLOIRJC (Reviewer's
Initials)Non-Public
Designation
Category:
MD 3.4 Non-Public
A.7 DOCUMENT NAME: g:\DRS\EB1\ohara\salem1-(2010003)(ohara)(isi-rpt)(7-21-
201 0)wbr3edits.doc
After declaring
this document An Official Agency Record" it will not be released to the Public.To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with+++ + '+, <'" +:++: :++44' '2 i "'+4 4 L + A+++ +;? '>4++++++++++>'.++ +++ i +A++ ::++ : +.+... .+ .. .+ .,+ + /', , OFFICE RI/DRS IT/DRS R1/DRS NAME TO'Hara/TLO
WSchmidt/wac
for RConte/RJC
___,,_-_____
DATE 07/21/2010
07/21/2010
07/22/2010
__________,_,__
OFFICE NAME 4 DATE ,: ,? + +++ .: +:+++++.,+
+} +, :.:.' .4, OFFICIAL RECORD COPY 4< .22 4 >44~.44~.44')'4 4 ,44444~4',
SUMMARY OF FINDINGS Reactor Safety Cornerstone:
Mitigating
Systems ne),for-iPSE',falr
o perform aL'i~i iry feedwater
syste~m (AFV discha'rge
ppn, t~y este~s on~ undppn opnnsa required by. 10 CFR 5O.55a(g)(4)
and the red nericaS~n~
of~t~ Megchanica['Engineers
Cod (S~) Section Xi 'paragra2h.
fo j6 ae Unit 2. The reqiJiredtr'6sts
are in endd o _peafce piri is sa-f ielated, MEClas's 3, i~cCIa 0 Op Ipingrf hiL erf, ace efiiency is mr e than minor becaue the con~dition
affected the EfqLýO et~_s ofneanute
~(availabilit
and rlaityof te mitigating
ssei~biesoe
~jecbve ~ ~'K 4 I"M 'Tcmi ndqie t1e9,1 ~visent"naie~P
'g, W M-Wa.m. on St rat R- stru 3M=V I IRA AKAGý he "Ann'af46Un it 2 'i-n-fe r- 1144W ni Ot -mlsivol 6081016, hodicati, f Pfoht his finding is described
in Section 1 R08.One violation
of very low safety significance, which was identified
by PSEG, was reviewed by the inspector.
Corrective
actions taken or planned by PSEG were entered into the corrective
action program. The violation
and corrective
action (notification)
tracking number is described
in Section 40A7 of this report.ii
REPORT DETAILS 1R08 Inservice
Inspection (ISI) (7111108-
1 Sample)a. Inspection
Scope The inspector
observed a selected sample of nondestructive
examination (NDE)activities
in process. Also, the inspector
reviewed the records of selected additional
samples of completed
NDE and repair/replacement
activities.
The sample selection
was based on the inspection
procedure
objectives
and risk priority of those components
and systems where degradation
would result in a significant
increase in risk of core damage.The observations
and documentation
reviews were performed
to verify that the activities
inspected
were performed
in accordance
with the American Society of Mechanical
Engineers (ASME) Boiler and Pressure Vessel Code requirements.
The inspector
reviewed the licensee's
performance
of a visual inspection (VT) of the Unit 1 reactor vessel closure head (RVCH) and the installed
upper head penetrations.
The inspector
reviewed the visual procedure, the qualifications
of the personnel
and reviewed the inspection
report documenting
the inspection
results. The inspector
also reviewed the data sheets for the penetrant
tests completed
on three of the penetration
welds of the RVCH.The inspector
reviewed records for ultrasonic
testing (UT), visual testing (VT), penetrant testing (PT) and magnetic particle testing (MT) NDE processes.
PSEG did not perform any radiographic
testing (RT) during this outage. The inspector
reviewed inspection
data sheets and documentation
for these activities
to verify the effectiveness
of the examiner, process, and equipment
in identifying
degradation
of risk significant
systems, structures
and components
and to evaluate the activities
for compliance
with the requirements
of ASME Code,Section XI.Steam Generator
Inspection
Activities
The inspectors
reviewed a sample of the Unit 1 steam generator
eddy current testing (ECT) tube examinations, and applicable
procedures
for monitoring
degradation
tubes to verify that the steam generator
examination
activities
were performed
in accordance
with the rules and regulations
of the steam generator examination
program, Salem Unit 1 steam generator
examination
guidelines, NRC Generic Letters, 1 OCFR50, technical
specifications
for Unit 1, Nuclear Energy Institute 97-06, EPRI PWR steam generator
examination
guidelines, and the ASME Boiler and Pressure Vessel Code Sections V and XI. The review also included the Salem Unit 1 steam generator
degradation
assessment
and steam generator
Cycle 21 and 22 operational
assessment.
The inspector
also verified the individual
certifications
for personnel
participating
during the 1R20 refueling
outage.j ~,~ ~~~-4, ~,~.d, ~.~-. ,, V .~., ~.*,,s ~~ ;&.4.,
2 The inspector
reviewed PSEG's efforts in identifying
wear degradation
to the tubing in the four SGs at Unit 1. The majority of the identified
wear indications
were attributed
to anti vibration
bar (AVB) wear in the u bend regions of the four SGs. The inspector reviewed the analyses and evaluations
that determined
that a total of 14 SG tubes would be removed from service by plugging.Boris Acid Corrosion
Control Program Activities
The inspector
reviewed the PSEG boric acid corrosion
control program. The resident inspectors
observed PSEG personnel
performing
boric acid walkdown inspections, inside containment, and in other affected areas outside of containment, at the beginning of the Unit 1 refueling
outage. The inspectors
reviewed the notifications
generated
by the walkdowns
and the evaluations
conducted
by Engineering
to disposition
the notifications.
Additionally, the inspector
reviewed a sample of notifications
and corrective
actions completed
to repair the reported conditions.
Section XI Repair/Replacement
Samples: AFW System Piping, Control Air & Station Air: The inspectors
reviewed PSEG's discovery, reporting, evaluation
and the repair/replacement
of Unit 1 AFW piping that was excavated
for inspection
during the April 2010 Unit 1 refueling
outage (1R20).PSEG conducted
this inspection
in accordance
with PSEG's Buried Piping Inspection
Program. Additionally, the inspectors
reviewed the UT testing results (approximately
20,000) performed
to characterize
the condition
of the degraded Unit 1 buried AFW piping.The inspector
also reviewed the repair/replacement
work orders and the 50.59 screening and evaluation
for the AFW, CA and SA piping. The inspectors
reviewed the fabrication
of the replacement
piping, reviewed the' documentation
of the welding and NDE of the replacement
piping and reviewed the pressure tests used to certify the replacement
piping. Additionally, the inspector
reviewed the specified
replacement
coating, the application
of the replacement
coating and the backfill of the excavated
area after the*piping had been tested.The inspector
reviewed the finite element analysis (FEA) results from PSEG's past operability
analysis on the affected Unit 1 buried AFW piping completed
by the licensee in order to demonstrate
at a reduced system pressure of 1275 psig. The design pressure of the AFW system is 1950 psig.The inspector
also reviewed the UT testing results (approximately
400) performed
on
of the Unit 2_AFWpiping
in response to the conditions
observed on Unit ." _men__4]__tlleleetht_"0at_
1 piping in order to determine
if significant
degradation
existed on the Unit 2 buried AFW .,..piping.Reiectable
Indication
Accepted For Service After Analysis: The inspector
reviewed the Notification
and the UT data report of a rejectable
wall thickness
measurement
elbow during 1 R20. The inspector reviewed the additional
wall thickness
data taken to further define the condition
and
3 reviewed the finite element analysis (FEA) which verified that sufficient
wall thickness remained to operate the component
until the next refueling
outage when it will be replaced.b. Finding The inspector
identified
the following
violation
related to ASME,Section XI testing of buried Unit I and Unit 2 buried AFW piping.introduction.
The inspector
identified
a GREEN non-cited
violation (NCV) of 10 CFR 50.55a(g)(4)
and the referenced
American Society of Mechanical
Engineers (ASME)Code,Section XI, paragraph
IWA-5244 for PSEG's failure to perform required pressure tests of buried components.
This piping is safety related, 4.0" ID, ASME Class 3, Seismic Class 1 piping.Description.
Portions of the Unit I and Unit 2 Auxiliary
Feedwater (AFW) System piping is buried piping and has not been visually inspected
since the plant began operation
in 1977 for Unit 1 and since 1979 for Salem Unit 2. In April 2010, approximately
680 ft.(340 ft. of the #12 SG AFW supply and 340 ft. of the #14 SG AFW supply) of piping between the pump discharge
manifold and the connection
to the Main Feedwater
piping to the affected SGs was discovered
to be corroded to below minimum wall thickness (0.278") for the 1950 psi design pressure of the AFW System. The discovery
was noted by PSEG during a planned excavation
implementing
their buried pipe inspection
program. The lowest wall thickness
measured in the affected piping was 0.077". PSEG plans on excavating
the Unit 2 buried piping to inspect the condition
during the next Unit 2 outage scheduled
for the spring of 2011. The affected Unit 1 piping was replaced.Although no leakage was evident for these conditions, the inspector
questioned
if periodic pressure tests had been conducted
on this underground
piping.10 CFR 50.55(a)(g)(4)(ii)
requires licensees
to follow the in-service
requirements
of the ASME Code,Section XI. Paragraph
IWA-5244 of Section Xl requires licensees
to perform es ssn buried components
to demonstrate
the structural
integrity_
of mnt[5] o, the tested piping. The pressure test required by IWA-5244 is considered
to be an et0unders larld th'at re, arrS retoV , m -s M inservice
inspection
and is part of Section XI.Section XI and IWA-5244 do not specify lihi other non-destructive
examinations (NDE) on buried components
to demonstrate
the ~obabl;' cbsser IftEfm existence
of structural
integrity.
-t n uirei 3e ° cnsayP.l
s u 3tpeln.k 6 , ; MOeti~'per" d__ Inera =° 1.L' '; 4 Thus PSEG ...
j 4did not to perform the only inservice
inspection, intended to ' ... efdemonstrate
the structural
integrity
of this safety related buried piping. ., PSEG sought relief, from the NRC, from the previous Code required pressure testing in 1988 for Unit 1 only. Relief was granted to PSEG, by the NRC,_to perform an alternate flow test in 1991 for Unit 1. However, t-ttet
n t .E e i testAung~h~2visericen~aari~
du~n~ the~ (i1901~o~6//04an&P.
!;A)-4.4.the
9l In Service insp cinIntenddvoamide
J Phuse 1 P SEG in7ciue CU Enfareen
4____ ~§fi~en~y
which~ff&6t~.
misse&~9pp___
I~reR¶i, ~cA~r rw t jfsu.~fl~rwl~~
PSEG replaced the affected buried Unit 1 piping during the refueling
outage in April/May 2010. The required pressure tests were successfully
completed
after the replacement
of the Unit 1 buried piping. Because the AFW system functioned
as required during the plant shutdown prior to the start of, 1R20 (April 2010), the system did not loose operability.
8 42Ilito p~er ct ikA h?6fo PSGretlaed
6~~t6iTtlthe
afe~ctd buredu let1piigdurteing
otaehereueing
fortag inArihg/2May
Analysis.
The req ired pre fore r t were qucrdssfullycom
tlieted af e repla t th Uit d brid i png ng. Becraus cyth ea sys em fu ctioe .as eqire odirionga
the perform the only inservice
inspection (IWA-5244), intended to provide-eviden
o demonstrate
the structural
integrity
of this safety related buried piping. , Thes oninetion
ascreened
th menperformance
d attinbyutesvin
abiMC ity9 Atacdhmenibltyo
imat he m~i~tigat
Cirnersstemorners~tine
tyodvesu'tel
afetn h ecnay hr permabilityfy
heat repova c Y Ljniii wasiurther
rOsultodpin
in a m erore niianc codeition
ducrtoac aen tined undtcctedcroion
wasthou pr ftr t15or e iirrelcesti'g
fo ilr et rcka e. tterýg 'f1 F tem ecy
ata, [1¶& inl ectbr "3Vf andtiee S EGCeq uestedghr m a&ac tionssf .. fi !je W g .-.ecte.. ... .n ... .. .. ..
5 Enforcement.
11hbatte srv61 LqsrzdwtrýrAed
ula oi6'T =r~ f~ilitcomiponents
ihare!cIassifiedas
VASME o~de, ClA~ss;, 1ls' 2ad, us nietýýfhe
rreq~imen'i-, Fa'rglra'1561IWA-52441
Bu~ried Qompon o etnXlsays, in P tha -F-o bu compbonbnts
whero ! -Yieacmntincht3j
9,1stenm pressuiretestfrbre
comp~onents
that ate isolable bmeans of valvesýshai~onsstof
1st thatV ~detris thdýrtepressttr.
loss. Atrilati!yel
t~1ýt--i ftký*, rh -iowf1-c pm_,fj2t-s. "I--------------------------
~~d~o 1 tha 0t eo'e6hae l~t~'rcMmendddetj~
addressF my Contrary to these requirements, PSEG did not perform the required pressure tests of the buried AFW piping to the #12 SG and #14 SG at Salem Unit 1 during the 2nd In Service Inspection
Interval (2/27/88 to 5/19/01) and during the 1st (5/19/01 to 6/3/04) and 2 nd (6/24/04 to 5/20/08) periods of the 3rd In Service Inspection
Interval (5/19/01 to 5/19/11).Also, contrary to these requirements, PSEG did not perform the required pressure tests of the buried piping to the #22 SG and #24 SG for Unit 2 for the 1st period (5/19/01 to 6/3/04) and 2nd period (6/24/04 to 5/20/08) of the 3rd In Service Inspection
Interval.Consequently, from 2/27/88 to 4/20/07) the required pressure tests were not performed to demonstrate
structural
integrity
on the affected buried-Unit
1 AFW piping.Because PSEG entered this condition
into the corrective
action process (Notification
20459686)
and because it is is of very low safety significance (Green), it is being treated as a non-cited
violation
consistent
with Section VI.A.1 of the NRC Enforcement
Policy.NCV 50-272/2010-??
and NCV 50-311/2010-??
40A2 Identification
and Resolution
of Problems (71152)a. Inspection
Scope The inspectors
reviewed a sample of corrective
action reports (notifications), listed in Attachment
2 which involved in-service
inspection
related issues, to ensure that issues are being promptly identified, reported and resolved.b. Findings No findings of significance
were identified.
40A5 Temporary
Instruction (TI) 2515/172 a. Inspection
Scope The Temporary
Instruction (TI), 2515/172 provides for confirmation
that owners of pressurized-water
reactors (PWRs) have implemented
the industry guidelines
of the Materials
Reliability
Program (MRP) -139 regarding
nondestructive
examination
and evaluation
of certain dissimilar
metal welds in the RCS containing
nickel based Alloys 600/82/182.
6 During 1R20 PSEG inspected
the dissimilar
metal weld on the 1" reactor vessel drain piping with no detected indications.
Salem Unit 1 has dissimilar
metal welds in the eight reactor coolant system piping to reactor vessel nozzle safe end welds. No additional
inspections
or MSIP applications
were performed
during 1R20.This TI requires documentation
of specific questions
in an inspection
report. The questions
and responses
for the IR 05000272/2010003
section 40A5 are included in this report as Attachment "B-I".b. Findings No findings of significance
were identified.
40A6 Meetings, includinq
Exit The inspectors
presented
the ISI inspection
and TI 2515/172 inspection
results to Mr. Ed Eilola, Salem Plant Manager, and other members of the PSEG staff at the conclusion
of the inspection
at an exit meeting on June 28, 2010 for Salem Unit 1. The licensee acknowledged
the conclusions
and observations
presented.
Some proprietary
information
was reviewed during this inspection
and was properly destroyed.
No proprietary
information
is contained
in this report.40A7 Licensee Identified
Violations
The following
violation
of NRC requirements
was identified
by PSEG. It was determined
to have very low significance (Green) and to meet the criteria of Section VI of the NRC Enforcement
Policy, NUREG-1600, for being dispositioned
as a non-cited
violation.
The
finding of very l.w safcy .igifi.a...
was identified
by PSEG. The finding is a violation
of 10 CFR 50, Appendix B, Criterion
III, Design Control that-requires
in part that measures shall be established
to assure that applicable
regulatory
requirements
and'design
bases are correctly
translated
into specifications, drawings, and instructions
and that these measures shall include provisions
to assure the proper selection
and review for suitability
of application
of materials, parts, equipment, and processes.
During pipe excavation
and inspections
conducted
as part of PSEGs buried piping program PSEG identified
that it did not provide an effective
protective
coating for the buried_section of AFW piping on Unit 1.PSEG identified
general corrosion
that reduced the wall thickness
of the safety related piping to less than the design minimum wall thickness
of 0.278" for the system design pressure of 1950 psig. The lowest measured wall thickness
was 0.077". An FEA for the degraded piping was able to demonstrate
past operabili
at a reduced operating pressure of 1275 psiorto gt~i r rhai A'1so w~ smtgatn s te~illlt f short erma decay heat removal.capability.The__na__gwas__emlet6be
Green_Ioss of.operabli 661RY,* -o .".O N .I.-.-- -------------------------.I.- -.-.-- ------------------------------------------------------------------
7 Because PSEG entered this condition
into the corrective
action process (Notification
20456999)
and because the issue is of very low safety significance (Green), this issue is being treated as a non-cited
violation
consistent
with Section VI.A.1 of the NRC Enforcement
Policy. NCV 50-27212010003-??
4; , ..~4 A K2. &~242PA-2 2 ~ 2~j ~~'2 2;,~22~j2 4 22~'22'22.
27~ '2-2~ 2-242 ~ 2><22.44~2~4~2~2~2.1/2'"2 4 '4'4P- '2-2-., 42'<4~42 44k 2 24~m 42>2 .4-44222 2244-2 2~ '~'~ 2,2 2 2~222~22 4'424 2,4 222
A-1 ATTACHMENT
SUPPLEMENTAL
INFORMATION
KEY CONTACTS Licensee Personnel:
~: ~Howard Berrick, PSEG Pat Fabian, PSEG Mohammad Ahmed, PSEG Tony Oliveri, PSEG Tom Roberts, PSEG Ali Fakhar, PSEG Len Rajkowski, PSEG Dave Mora, PSEG Edley Giles, PSEG Walter Sheets, PSEG Bob Montgomery, PSEG Jim Mellchiona, PSEG Bill Mattingly, PSEG Pat Van Horn, PSEG Jim Barnes, PSEG Justin Werne, PSEG Rick Villar, PSEG Matthew Murray, PSEG'4 44" LIST OF DOCUMENTS
REVIEWED Notifications:
20457869, Control Air Piping Leak*20462034, Basis AFW Discharge
Line Design Pressure*20461785, Untimely retrieval
of Design Documents*
20461255, U2 Containment
Liner Blisters*20459259, U2 Containment
Liner Blisters*20459689, failure to do IWA-5244 pressure tests*20456999, Guided Wave (GW) pipe wall loss 20% to 44%*, in Equipment
Apparent Cause Evaluation (EQ;ACE) Charter 20457854, see Equipment
Apparent Cause Evaluation (EQ: ACE) Charter 20457869, Air Line Leak, in Equipment
Apparent Cause Evaluation
EQ: ACE Charter 20458147, see Equipment
Apparent Cause Evaluation (EQ: ACE) Charter 20458148, see Equipment
Apparent Cause Evaluation (EQ: ACE) Charter 20458568, see Equipment
Apparent Cause Evaluation (EQ: ACE) Charter 20458554, 11 CA HDR Line In Fuel Xfer Area Degraded*20458761, 1R20 CA Buried Pipe Coating Repair*20458925, 1 R20 SA Buried Pipe Coating Repair*.20457262, (88) 1R20 AF Buried Pipe Inspection
Results*20460624, Need Heat Trace on AF lines in FFT Area 20457877, UI Containment
Liner Corrosion
at 78' El.*i 4~AV '~<
flt.< *> y(. *t.. -(4 ~ ~4W~'i A-2 20459259, Ul Corrosion
on Containment
Liner*20459303, #14 AF pipe damaged penetration
seal*20459304, #12 AF pipe damaged penetration
seal*20459454, Request for Additional
UT Data, 4/18/10 (due to 0.077" reading)*20344017, Inspect steel liner in 1R19 20235636, NRC noted water running down containment
wall 20459189, Question on location of RFO-14 location of a PZR shell weld 20290560, Replace section of 15B FWH shell-S1-R18
20457879, (184) 1R20 FAC(N18) 14# elbow below Tmin 20456828, (66) valve has visible boron buildup 1 R20 20459232, Heavy Dry White Boron VIv Packing (1 R20)20456834, Heavy Dry White Boron VIv Packing (1 R20)20456840, Medium Dry White Boron VIv Packing (1 R20)20456839, Medium Dry. White Boron Vlv Packing (1R20)20389147, Recordable
ISI Indications
on CVC Tank 20344017, Inspect Steel Liner in 1R19 @ Containment
Sump 20235636, NRC Noted Water Running Down Containment
Wall 20392631, ARMA From ISI Program Audit 2008 20460624, Need Heat Trace on AF lines in FTT Area 20333050, Response to NRC NOV EA-07-149 20322039, 2 nd Interval ISI NRC Violation 20397518, A1CVC-1CV180
Chk VIv Stuck Open -PI&R review 20444514, Boric Acid Leak from Drain Line -PI&R review 20445314, boron leak -PI&R review 20448241, Minor Packing Leak -BAC -PI&R review 20435861, 21SJ313 Has Boric Acid Leakage -PI&R review 20417331, Boric Acid Leak at 11 CV156 -PI&R review 20411151, Tubing leak on 1SS653 -PI&R review 20414343, 12 Charging Pump seal inj. Line -PI&R review 20395346, 12 Bat PP Seal Leak -PI&R review 20450330, Containment
Liner Corrosion
-PI&R review 20385733, Severe Corrosion
on FP Valve -PI&R review 20438320, (217) Op Eval. Of Containment
Corrosion
-PI&R review 20387897, Significant
outlet pipe corrosion
-PI&R review 20397225, MIC Corrosion
Causing Through Wall Leak -PI&R review 20436836, Repair Cracks in Battery Cells -PI&R review 20392145, Update U1 ISI Relief Request Book -PI&R review 20449447, Update Salem Unit 1 ISI 10 Yr Plan -PI&R review 20449744, Update Salem Unit 1 Containment
ISI 10 Yr Plan -PI&R review 20449442, Update Salem Unit 2 Containment
ISI 10 Yr Plan -PI&R review 20449554, Salem U2 RFO18 ISI Scope -PI&R review 20416605, INPO PSIRV Alloy 600 Program -PI&R review 20404057, Unit 2 ISI (MSIP) -PI&R review 20392631, ARMA FROM ISI PROGRAM AUDIT 2008 -PI&R review 20388065, Water leaking in decon room -PI&R review 20439023, 23 CFCU Head Leakage -PI&R review 20439022, SW Header Leakage 23 CFCU -PI&R review 20389148, 1R19 ISI Weld Exam Limitations
-PI&R review 20416605, INPO PSIRV Alloy 600 Program -PI&R review 20449442, Update Salem 2 Containment
ISI 10 yr. Plan -PI&R review 20449554, Salem Unit 2 RFO18 ISI Scope -PI&R review 4 4 w~.44, A'((9, 4,~ ~'4 ".4 4<, 4'../ '>~44944 444~'.. ~4~44( (~,"-'4 4 44 4 .4'4,4 4~4, 4'4'
A-3 C" 20449747, Update Salem 2 ISI 10 Yr. Plan -PI&R review 20401542, Perform ISI BMV Exam on RPV Upper Head -PI&R review 20449063, SA Ul Service Inspec- ISI & U1 TI 2515 -PI&R review 20389147, Recordable
ISI Indications
on CVC Tank -PI&R review 20392145, Update Ul ISI Relief Request Book -PI&R review 20449744, Update Salem U1 Containment
ISI 10 Yr. Plan -PI&R review 20409943, NRC RIS 2009-04 SG Tube Insp Rqmts -PI&R review 20459851, Section Xl Exams Limited to 90% or Less -PI&R review 20450520, Recoat Affected Areas of Liner 2R18 -PI&R review 20457388, Excavation
Issues -PI&R review*Denotes this Notification
was generated
as a result of this inspection
Section XI Repair/Replacement
Samples: Y1A~i ~~; '4h:;;* <'1'~" '1~4~< ~'4', ~&r~Y~ >~k" ~1/2& >.& 'W.O. 60079414,14" Carbon Steel Elbow FAC indication
below minimum wall W.O. 60084266, Salem Ul AF Buried Piping Inspection
W.O. 60089561, 80101381:
Replace Aux FW U/G Piping W.O. 60064104, Repair 15B FWH Area W.O. 60084375, BACC Program repair to 1PS1 W.O. 60089612, BACC Program repair to SlCVC-14CV392
W.O. 60089615, BACC Program repair to S1SJ-13SJ25
W.O. 60089848, 80101382 Advanced Work Authorization
- 2 FTTA Replace Aux. Feedwater Pipe W.O. 60089561, 80101381 Advanced Work Authorization
-Replace Aux. FW U/G Piping, 4/9/10 Non-Code Repair W.O. 60089848, Repair Non-nuclear, safety related CA Pipe, Unit 1 FTTA W.O. 60089757, Test Non-nuclear, safety related CA Pipe Repair, Unit 1 FTTA Miscellaneous
Work Orders: '&4<4,.-<~4< 4~'V ,~7 4~ -.~4 ,4 7 , ,,',." W.O. 60089917, Penetrations
for CA & SA Lines, 4/23/10 W.O. 941017262, Activity 04, Excavate and Examine Auxiliary
Piping, W.O. 941017262, Activity 03, Excavate and Examine Auxiliary
Piping, W.O. 941017262, Activity 02, Excavate and Examine Auxiliary
Piping, W.O. 941017262, Activity 01, Excavate and Examine Auxiliary
Piping, W.O. 60089561, Flush New AFW piping 12 and 14 Unit 2, 12/94 Unit 2, 12/94 Unit 2, 12/94 Unit 2, 12/94 I~ 4 ~'Drawings & Sketches: 205236A8761-54, Salem Nuclear Generating
Station, Unit No. 1, Auxiliary
Feedwater Salem Unit 1 Aux Feed Piping, Allan Johnson, 4/10/10 80101381 RO, Buried Pipe, Replaced AFW Piping Arrangement
207483A8923-1
1, Salem Nuclear Generating
Station, Unit No. 1 -Reactor Containment
Auxiliary
Feedwater, Plans & Sections -Elev. 78' 10" & 100' 0", Mechanical
Arrangement, Revision 8, 9/31/86 C""~, ~K:
A-4 207483A8923-28, Sheet I of 4, Salem Nuclear Generating
Station, Unit No. 1 -Reactor Containment
Auxiliary
Feedwater, Plans & Sections -Elev. 84',Mechanical
Arrangement, Revision 8, 9/31/86 207483A8923-31, Sheet 2 of 4, Salem Nuclear Generating
Station, Unit No. 1 -Reactor Containment
Auxiliary
Feedwater, Plans & Sections -Elev. 84', Mechanical
Arrangement, Revision 8, 9/31/86 207483A8923-28, Sheet 3 of 4, Salem Nuclear Generating
Station, Unit No. 1 -Reactor Containment
Auxiliary
Feedwater, Plans & Sections -Elev. 84', Mechanical
Arrangement, Revision 8, 9/31/86 207483A8923-30, Salem Nuclear Generating
Station, Unit No. 1 -Reactor Containment
Auxiliary
Feedwater, Plans & Sections -Elev. 84',Mechanical
Arrangement, Revision 8, 9/31/86 207610A8896-12, Salem Nuclear Generating
Station, Unit No. 1 -Auxiliary
Building & Reactor Containmnet
Compressed
Air Piping, Aux. Building El. 84 East & React. Contain. El. 78, Mechanical
Arrangement, Revision 8, 9/31/86 Design Change Packages/Equivalent
Change Packages 80101382, Revision 2, Replace Salem Unit 1 AFW Piping from the UnitMechanical
Area El. 78'-0" to the Unit 1 Fuel Transfer Tube Area El. 100'-0" 80101381, Revision 1, Replace in-kind the Salem Unit 1 AF Piping that runs underground
from the Unit 1 Fuel Transfer Tube Area to the Unit 1 Main Steam Outer Penetration
Area Y~,~ ~;<~ ~50.59 Applicability
Reviews, Screenings
& Evaluations
80101382;
Salem Unit 1 12/14 AF Piping Reroute; 4/24/10 System & Program Health Reports & Self-Assessments:
Salem Boric Acid Corrosion
Control Program Focused Area Self-Assessment, 1/2010 70106830, Salem $1R20 NRC ISI Inspection
Check-In Self Assessment
70095327, Salem Boric Acid Corrosion
Control Program Focused Area Self-Assessment, 4/29/09 Pro-gram Documents PSEG Nuclear Salem Units 1 & 2, Alloy 600 Management
Plan, Long Term Plan (LTP), Revision 2, Integrated
Strategic
Plan For Long Term Protection
from Primary Water Stress Corrosion
Cracking (PWSCC), 10/15/09 ASME, Section X1,1998 Edition, 2000 Addenda, IWA-5244 Buried Components
OAR-i, Owner's Activity Report, #S1RFO19, 1/15/09 r~t
A-5 Procedures
DETAILED AND GENERAL, VT-1 AND VT-3 VISUAL EXAMINATION
OF ASME CLASS MC AND CC CONTAINMENT
SURFACES AND COMPONENTS
SHRA -AP.ZZ -8805(Q) -Revision 4, 8/31/06; Boric Acid Corrosion
Management
Program ER -AP -331, Revision 4, Boric Acid Corrosion
Control (BACC) Program ER -AP -331 -1001, Revision 2, Boric Acid Corrosion
Control (BACC) Inspection
Locations, Implementation
And inspection
Guidelines
ER -AP -331 -1002, Revision 3, Boric Acid Corrosion
Control (BACC) Program Identification, Screening, and Evaluation
ER -AP -331 -1003, Revision 1, RCS Leakage Monitoring
And Action Plan ER -AP -331 -1004, Revision 2, Boric Acid Corrosion
Control (BACC) Program Training and Qualification
ER -AA -330 -001, Revision 7, SECTION XI PRESSURE TESTING LS -AA -125, Revision 13; Corrective
Action Program (CAP) Procedure LS -AA -120, Revision 8; Issue Identification
And Screening
Process SH.RA-IS.ZZ-0005(Q)-Revision
6; VT-2 Visual Examination
Of Nuclear Class 1, 2 and 3 Systems SH.RA-IS.ZZ-0150(Q)
-Revision 8, 10/19/04;
Nuclear Class 1, 2, 3 and MC Component Support Visual Examination
OU-AP-335-043, Revision 0; BARE METAL VISUAL EXAMINATION (VE) OF CLASS I PWR COMPONENTS
CONTAINING
ALLOY 600/82/182
AND CLASS 1 PWR REACTOR VESSEL UPPER HEADS OU-AA-335-015, Revision 0; VT 2 -VISUAL EXAMINATION
Areva NP, Inc., Engineering
Information
Record 51-9118973-000;
Qualified
Eddy Current Examination
Techniques
for Salem Unit 1 Areva Steam Generators, 10/15/09 AREVA NP 03-9123233, Revision 000, 10/13/09;
Salem Unit 2 RVCH Flange Repair SC.MD-GP.ZZ-0035(Q)
-Revision 9, PRESSURE TESTING OF NUCLEAR CLASS 2 AND 3 COMPONENTS
AND SYSTEMS, 02/02/10 SH.MD-GP.ZZ-0240(Q)
-Revision 10, SYSTEM PRESSURE TEST AT NORMAL OPERATING PRESSURE AND TEMPERATURE, 7/29/09 S2.OP-AF-0007(Q)-Revision
20, 12/23/09;
INSERVICE
TESTING AUXILIARY
FEEDWATER VALVES, MODE 3 ER-AA-5400-1002, Revision 1, BURIED PIPING EXAMINATION
GUIDE Specification
No. S-C-MPOO-MGS-0001;
Piping Schedule SPS54, Auxiliary
Feedwater, Revision 6 PSEG Test Procedure
10-H-8-R1, Unit 2 Auxiliary
2100/2150
Hydro; 9/21/78 NDE Examination
Reports & Data Sheets>~~r~rJ~ ~;9~ ~ j 003753, VT-10-113, PRV nozzle sliding support 003754, VT-10-114, RPV nozzle sliding support 006325, UT-10-041, PZR longitudinal
shell weld J (100%)007500, UT-10-132, PZR surge line nozzle (100%)007901, UT-10-028, 13 SG lower head to tubesheet
weld (67%)006073, VE-10-026, CRDM TO VESSEL PENETRATION
WELD, 4/12/10 008001, VE-10-027, 31-RCN-1 130-IRS 008026, VE-1 0-028, 29-RCN-1 130-IRS 009070, VE-10-030, 12-STG Channel Head Drain (100%)033300, UT-10-027, 4-PS-1131-27
(100%)033200, UT-10-029, 4-PS-1 131-26 (100%)9 $
A-6 033100, UT-1 0-032, 4-PS-1 131-25 (100%)032300, UT-10-033, 4-PS-1131-17
(100%)031700, UT-1 0-040, 4-PS-1 131-12 (100%)032600, UT-10-034, 4-PS-1 131-20 (100%)047600, UT-1 0-045, 29-RC-1 140-3 (100%)051200, UT-1 0-048, 29-RC- 1120-3 (100%)203901, UT-10-047, 32-MSN-2111-1
(100%)204001, UT-10-046, 16-BFN-2111-1
(70.64%)210586, UT-10-025, 14-BF-2141-19
(100%)210588, UT-10-024, 14-BF-2141-20
(100%)836300, IWE: VT-10-338, PNL-S1-343-1
836400, IWE: VT-10-333, ALK-Sl-100-tubing
840000, IWE: Vert Leak Channels 1 -14 006073, VE-10-026, RPV Upper Head Inspection
006051, PT-1 0-004, CRDM Housing Weld Exams, penetrations
- 66, 67, and 72 Salem Unit 1, VT-2, Visual Examination
Record, 12/14 AF FTTA, W.O. 60089848, 4/26/10 (VT)Salem Unit 1, VT-2, CA Repair Snoop Test, W.O. 60089575, 4/27/10 Salem Unit 1, UT, W.O. 60084266, Yard AF, 4/18/10 Salem Unit 2, UT, W.O.60089851, Exam of containment
liner Salem Unit 1, UT 1-SGF-31-L2
FW elbow below min. wall Salem Unit 1, UT, W.O. 30176541, 1-SGF-31-L2
FW elbow below min. wall Salem Unit 1, UT, W.O. 60084266, AFW Order 50113214, ST 550D, Surveillance:
ISI Perform PORV Check Order 50118090, ST 550D, Surveillance:
OPS Perform PORV Check W.O. 60089848, VT-2 Visual Examination
Record, 12/14 AFW in FTTA, 4/26/10 W.O. 941017262, Activity 02; Salem Unit 2, Excavate and Examine Auxiliary
Piping, 12/2/94 W.O. 60084266, UT Unit 1 AFW (thinnest
area), 4/20/10 UT Analysis, Component
1-SGF-31-L2
(14" FW Elbow below Minimum wall), 4/10/10 W.O. 60089851, Unit 2 Containment
Liner blister UT measurements, 4/21/10 W.O. 60086175, Unit 1 Containment
corrosion
78' elevation W.O. 60084266, Unit 1 AFW piping UT measurements, 4/12/10 W.O. 30176541, Unit 1 AFW piping UT measurements, 4/12/10 W.O. 60084266, Unit 1 AFW piping UT measurements, 4/7/10 W.O. 60084266, Unit 1 AFW piping UT measurements, 4/5/10 W.O. 60084266, Unit 1 AFW pipe UT measurements
at supports, 4/18/10 W.O. 30176541, Unit 1 CA piping UT measurements
in FTTA 401600, VE-04-198;
Hope Creek system pressure test CST to HPCI/RCIC
and Core Spray, 11/5/04 VT-2, Salem Unit 1 AF 12 & 14 Pressure Test, 4/25/10 W.O. 60089661, UT measurements, Unit 2 AFW Piping #24 in FTTA, 4/25/10 W.O. 60089661, UT measurements, Unit 2 AFW Piping #22 in FTTA, 4/26/10 2 T~~2~4,<A~. ,~.#-..41-4- ,>2 41
A-7 Eddy Current Testing Personnel
Qualification
Records A2421 88731 80500 B5127 B5128 B2576 F3961 C1560 D7895 D9573 D6502 H2039 K5380 M9460 E0427 M6664 84260 A3502 J9815 P5436 M6042 B8589 84014 G2573 V8530 W3368 M4305 84052 K6975 G391 0 H0268 L3025 P1465 B8079 G1756 C8071 6410058746
B5371 H2131 2909965330076
C2028 C4596 C3340 D3858 H6267 H0282 14048 J 1978 2010983302133
P6459 R0830 Ri1164 S0608 2509981330193
K5858 1007951330114
L9168 L4332 F7460 F0037 317943330158
6206070744
6507061922
1803983330125
2709977301226
P5304 P4006 R4201 R6452 R8002 S7752 T8251 V3197 R4142 R6279 G3380 83720 R6900 A9608 N2574 13805.T2170 N4815 M0945 P2963 M9715 K1 903 D5318 W6070 M5096 J1945 L4588 C8042 N5330 L8267 F3453 T5616 R931 1 G4943 C5542 F0075 F6623 F3453 G4943 G1311 H7791 J9141 M0950 M2665 M7006 M9459 M7007 M9082 N7035 N9952 R9311I S9098 T5616 T5565 W2639 W7912 2224222'24~'22 4'222.2 22 2'22' '1 22~ .2222, 24222~22.
222 '2 2222.~&~>222422222'
~22&142 22 2222 2' 2222224 ~2.242,2 S~422~ ~2 ~ 4~ ~ 2 242.~4. 242~ '4- '2 22 4~ 24f2~2 2~2 2244 22 2222~2'. %.22~~ ~2~2 2~2~222 '~K2~2~" >2~2' ~212 222,1 2 '2'222 22 2' 224224222242
2222>' 222 22,1222 K>422 74222242.24442422242
242 '722' 22 ,2222~ .4.2222~722 24'"" 2 2.2 42 2, 22<2 *2 K.2..2222 2 2.22 22: ,2 22
A-8 Engineerinq
Analyses & Calculations
& Standards Calculation
6SO-1882, Revision 1, 8/30/96; Qualification
of Safety-Related
Buried Commodities
For Tornado Missle and Seismic Evaluation
Calculation
No. S-C-AF-MDC-1
789; Salem Auxiliary
Thermal Hydraulic
Flow Model, 10/4/00 70087436, Steam Generator
Degradation
& Operational
Assessment
Validation, Salem Unit 1 Refueling
Outage 18 (1R18) & Cycles 19/20, 9/2008 51-9052270-000, Update -Salem Unit 1 SG Operational
Assessment
At 1R18 For Cycles 19 and 20, 10/1/08 51-9048311-002, Salem Unit 1 SG Condition
Monitoring
For 1R18 And Preliminary
Operational
Assessment
For Cycles 19 and 20, 10/30/07 701086998-0050, Maximum Pressure in Underground
Auxiliary
Piping 60089575-130, Past Operability
Determination
for the leak in the one inch air line to air operated valves in Unit 1 South Penetration
Area 70109233/20459231;
Boric Acid evaluation
of leakage from S1CVC-1CV277
70109232/20459230;
Boric Acid evaluation
of leakage from S1CVC-1 CV2 70109230/20459228;
Boric Acid evaluation
of leakage from S2RC-1PS1 70109234/20459232;
Boric Acid evaluation
of leakage from S1 SJ-13SJ25 70108698/30, Operating
Experience
Report for degraded Unit 1 AFW piping 51-9135923-000, AREVA; Salem unit 1 SG Condition
Monitoring
For 1R20 and Preliminary
Operational
Assessment
For Cycles 21 And 22, 4/20/10 SA-SURV-2010-001, Revision 1; Risk Assessment
of Missed. Surveillance
-Auxiliary Feedwater
discharge
line underground
piping pressure testing, 4/23/10 CQ9503151526;
SCI-94-0877,'EXCAVATED
AUXILIARY
PIPING WALKDOWN/DISPOSITION
OF COATING REQUIREMENTS;
12/16/94 Specification
No. S-C-M600-NDS-019, COATINGS INTERIOR/EXTERIOR
SURFACES CARBON STEEL SERVICE WATER PIPING, NO. 12 COMPONENT
COOLING HEAT EXCHANGER
ROOM AUXILIARY
BUILDING (ELEVATION
84)Structural
Integrity
Associates, Inc. Calculation
File No. 1000494.301, Evaluation
of Degraded Underground
Auxiliary
Piping (Between Unit 1 FTTA and OPA), 4/23/10 Technical
Evaluation
60089575-0140, Acceptability
of CA Piping in the Fuel Transfer Area, 4/29/10 Technical
Evaluation
60089848-0960, Auxiliary
Piping Missle Barrier Exclusion, 4/29/10 Structural
Integrity
Associates, Inc. Calculation
File No. 1000498.301, Evaluation
of Thinned Feedwater
Elbow, 4/22/10 Technical
Evaluation
70108698-0050, Maximum Pressure in Underground
Auxiliary
Feedwater Piping, 4/29/10 SPECIFICATION
NO. S-C-MPOO-MGS-0001, Piping Schedule SPS54 AUXILIARY FEEDWATER, Revision 6 OpEval. #10-005, Salem Unit 2 Operability
Evaluation, Received 5/18/10 Technical
Evaluation
60084266-105-20, Alternative
Exterior Coatings for Buried Piping, AF, CA, SA and Pipe Supports Under W.O. 60084266, 4/2/10 Technical
Evaluation
H-1-EA-PEE-1871, Hope Creek Service Piping Coatings Alternatives, 80075587, Revision 0, 10/15/04 PSEG Nuclear, LLC, Technical
Standard, Coating Systems and Color Schedules, Revision 5, 4/3/06.~.,~4 4 7w* .,. <AZ. -Y...7w.
A-9 Weld Records -AFW Piping Repair (W.O. #'s 60084266, 60089561, 60089798, 60089848)Multiple Weld History Record: 74626 Multiple Weld History Record: 74556 Multiple Weld History Record: 74557 Multiple Weld History Record: 74558 Multiple Weld History Record: 74559 Multiple Weld History Record: 74560 Multiple Weld History Record: 74561 Multiple Weld History Record: 74562 Multiple Weld History Record: 74563 Multiple Weld History Record: 74564 Multiple Weld History Record: 74565 Multiple Weld History Record: 74566 Multiple Weld History Record: 74567 Multiple Weld History Record: 74627 Multiple Weld History Record: 74569 Multiple Weld History Record: 74599 Multiple Weld History Record: 74623 Multiple Weld History Record: 74600 Multiple Weld History Record: 74630 Multiple Weld History Record: 74622 Multiple Weld History Record: 74578 Multiple Weld History Record: 74596 Multiple Weld History Record: 74601 Multiple Weld History Record: 74602 Multiple Weld History Record: 74603 Multiple Weld History Record: 74604 Multiple Weld History Record: 74605 Multiple Weld History Record: 74598 Multiple Weld History Record: 74606 Multiple Weld History Record: 74607 Multiple Weld History Record: 74608 Multiple Weld History Record: 74609 Multiple Weld History Record: 74610 Multiple Weld History Record: 74611 Multiple Weld History Record: 74612 Multiple Weld History Record: 74613 Multiple Weld History Record: 74614 Multiple Weld History Record: 74615 Multiple Weld History Record: 74597 Multiple Weld History Record: 74616 Multiple Weld History Record: 74579 Multiple Weld History Record: 74580 Multiple Weld History Record: 74581 Multiple Weld History Record: 74582 Multiple Weld History Record: 74583 Multiple Weld History Record: 74595 Multiple Weld History Record: 74584 Multiple Weld History Record: 74585 Multiple Weld History Record: 74586 I,
A-10 Multiple Weld History Record: 74587 Multiple Weld History Record: 74588 Multiple Weld History Record: 74589 Multiple Weld History Record: 74590 Multiple Weld History Record: 74591 Multiple Weld History Record: 74592 Multiple Weld History Record: 74593 Multiple Weld History Record: 74577 Multiple Weld History Record: 74625 Multiple Weld History Record: 74574 Multiple Weld History Record: 74624 Multiple Weld History Record: 74573 Multiple Weld History Record: 74572 Multiple Weld History Record: 74570 Multiple Weld History Record: 74571 Multiple Weld History Record: 74623 Multiple Weld History Record: 74622 Multiple Weld History Record: 74621 Multiple Weld History Record: 74537 Multiple Weld History Record: 74538 Multiple Weld History Record: 74537 Welder Stamp Number: P-664 Welder Stamp Number: P-65 Welder Stamp Number: P-466 Welder Stamp Number: P-57 Welder Stamp Number: E-64 Welder Stamp Number: P-710 Welder Stamp Number: P-207 Welder Stamp Number: P-666 Welder Stamp Number: P-708 Welder Stamp Number: E-89 Welder Stamp Number: P-84 Welder Stamp Number: P-228 Surface Exam Record: 60089561-0041
Surface Exam Record: 60089848-0001
Surface Exam Record: 60089848-0001
Surface Exam Record: 60089561-0041
Surface Exam Record: 60089561-0860
~.4 v4~9'Miscellaneous
Documents Salem Unit 1 & Salem Unit 2 Technical
Specification, 3.4.11 STRUCTURAL
INTEGRITY, ASME CODE CLASS 1, 2 AND 3 COMPONENTS
Electric Power Research Institute (EPRI), Steam Generator
Integrity
Assessment
Guidelines, Technical
Report 1012987, Revision 2, July 2006 NRC Letter dated 3/11/91; FIRST TEN-YEARINSPECTION
INTERVAL, INSERVICE INSPECTION
PROGRAM RELIEF REQUEST, SALEM NUCLEAR GENERATING
STATION, UNIT 1 (TAC NOS. 66013 AND 71101)PSEG Nuclear, Salem Unit 1 & 2 Alloy 600 Management
Plan, Long Term Plan (LTP), Revision 2, 10/15/09 Salem Unit 1 -Buried Piping Risk Ranking
A-11 MPR Associates
Report, Technical
Input To Operability
of Potential
Containment
Liner Corrosion, Revision 0, 10/30/09 Transmittal
of Design Information
- S-TODI-2010-0005, 4/20/2010 Transmittal
of Design Information
- S-TODI-2010-0004, 4/16/2010 OQ950315126, PSEG Itr. Dated 12/16/94;
Excavated
Auxiliary
Piping Walkdown/Disposition
of Coating Requirements
PSEG letter LR-N07-0224
dated 9/13/2007;
REPLY TO NOTICE OF VIOLATION
EA-07-149 UNTAGGING
WORKLIST 4274446,14
AF Underground
Piping 1 R20, 4/30/10 UNTAGGING
WORKLIST 4274351, 12 AF Underground
Piping 1R20, 4/30/10 LIST OF ACRONYMS ASME BAST CEA CEDM CFR EDG EPRI EQ;ACE EQ ER FEA FTTA IMC IP IR LER LOCA MT MSIP NCV Notification
NRC NDE OE PDI PI&R PSEG PWSCC PQR RCS RT PT SDP SE American Society of Mechanical
Engineers Boric Acid Storage Tank Control Element Assembly Control Element Drive Mechanism Code of Federal Regulations
Emergency
Diesel Generator Electric Power Research institute Equipment
Apparent Cause Evaluation
Environmental
Qualification
Engineering
Request Finite Element Analysis Fuel Transfer Tube Area Inspection
Manual Chapter Inspection
Procedure NRC Inspection
Report Licensee Event Report Loss of Coolant Accident Magnetic Particle Testing Mechanical
Stress Improvement
Process Non-cited
Violation Corrective
Action Notification
Nuclear Regulatory
Commission
Nondestructive
Examination
Operating
Experience
Performance
Demonstration
Initiative
Problem Identification
and Resolution
Public Service Electric & Gas, LLC Primary Water Stress Corrosion
Cracking Procedure
Qualification
Record (Welding Procedures)
Reactor Coolant System Radiographic
Test (Radiography)
Dye Penetrant
Testing Significance
Determination
Process Safety Evaluation
Ky~~K~K ~K?" K ~"K k'-
SG SI SSC TS UT UFSAR VT WPS A-12 Steam Generator Stress Improvement
Structure, System, and Component Technical
Specifications
Ultrasonic
Test Updated Final Safety Analysis Report Visual Examination
Weld Procedure
Specification
v4~:~fl~~~>y.~4
4'4' '?~A-13 INSPECTION
SAMPLE COMPLETION
STATUS PROCEDURE
MINIMUM CURRENT RPS PROCEDURE
RPS or TI REQUIRED INSPECTION
TOTAL STATUS UPDATED SAMPLES SAMPLES SAMPLES OPEN (O) (Y) (N)Annual (A) TO DATE CLOSED (C)Biennial (B)7111108 (G) 1 Y 2515/172 1 YES 4'$~~$*4~$4>
4~V'W 4.'-K "~k~$ ~&: K.U' ~'$4 '4>4'> K'K>'*4~$$4$4 4.'4~>'>'*A' A>.'
A -14 , Attachment
B-1 TI 172 MSIP Documentation
Questions
Salem Unit I Introduction:
The Temporary
Instruction (TI), 2515/172 provides for confirmation
that owners of pressurized-water
reactors (PWRs) have implemented
the industry guidelines
of the Materials
Reliability
Program (MRP) -139 regarding
nondestructive
examination
and evaluation
of certain dissimilar
metal welds in the RCS containing
nickel based Alloys 600/82/182.
This TI requires documentation
of specific questions
in an inspection
report.The questions
and responses
for MSIP for the IR 05000311/2009005
section 40A5 are included in this Attachment "B-i".In summary the Salem Units 1 and 2 have MRP-139 applicable
Alloy 600/82/182
RCS welds in the four hot and four cold leg piping to reactor pressure vessel nozzle connections
for each plant.For Unit 1 during the 1R20 refueling
outage in April 2010 PSEG inspected
one dissimilar
metal'weld, a SG channel head drain line weld. No indications
were reported from this inspection.
PSEG plans on replacing
this valve, and the dissimilar
metal weld, during refueling
outage 1 R22.TI 2515/172 reauires the followina
a uestions to be answered for MRP-139 MSIP inspections:
- 7w<<I~ K I ~'A~fr ~V.-'A: &V,,-'A,."A 'A'~A~$" ,'~ ~"#--'~"""V ~K$~2':~"A"'~
Question 1: For each mechanical
stress improvement
used by the licensee during the Salem U1 1 R20 outage, was the activity performed
in accordance
with a documented
qualification
report for stress improvement
processes
and in accordance
with demonstrated
procedures?
Response Question 1: No MSIP activities
were conducted
on UI during 1R20.Question d.l: Are the nozzle, weld, safe end, and pipe configurations, as applicable, consistent
with the configuration
addressed
in the stress improvement (SI) qualification
report?Response-
Question d.l: No MSIP activities
were conducted
on U1 during 1R20.Question d.2.: Does the SI qualification
report address the location radial loading is applied, the applied load, and the effect that plastic deformation
of the pipe configuration
may have on the ability to conduct volumetric
examinations?
Response Question d.2: No MSIP activities
were conducted
on U1 during 1 R20.Question d.3.: Do the licensee's
inspection
procedure
records document that a volumetric
examination
per the ASME Code,Section XI, Appendix VIII was performed
prior to and after the application
of the MSIP?Response:
Question d.3.: No MSIP activities
were conducted
on U1 during 1 R20.
A-1 5 Question d.4.: Does the SI qualification
report address limiting flaw sizes that may be found during pre-SI and post-SI inspections
and that any flaws identified
during the volumetric
examination
are to be within the limiting flaw sizes established
by the SI qualification
report?Response:
Question d.4.: No MSIP activities
were conducted
on U1 during 1 R20.Question d.5.: Was the MSIP performed
such that deficiencies
were identified, dispositioned, and resolved?Response Question d.5.: No MSIP activities
wereconducted
on U1 during 1 R20.5'>Y2~ 4: 5<', YI~~42>5 55 5~' 5'~'55'5 5
I think that we missed the point here. As defined in MC 0612 a performance
deficiency
is an issue that is the result of a licensee not meeting a requirement
or standard where the cause was reasonably
within the licensee's
ability to forsee and correct, and therefore
should have been prevented.
PSEG did not meet the CFR because they did not perform the testing, not the other way around. What was the result/the
impact on the safety of the public by not performing
the required testing? It is necessary
to define thise result in order to evaluate the significance
-that is why the definition
is written that way. Not using the following
words exactly one suggestion
for defining the result would be -due to the condition
of the pipe and coating identified
during the excavation, it is clear that the failure to perform required testing would have ultimately
resulted a loss of structural
integrity
for the pipe impacting
the operability
of the affected AFW trains.This does not meet the MC 0612 documentation
requirements.
Needs to address all the screening
criteria.
A more appropriate
statement
would be something
like this. The inspectors
determined
the issue was of very low safety significance (Green) because the finding was not a design or qualification
deficiency, did not result in an actual loss of safety function, and was not potentially
risk significant
for external events.