ML102990179
| ML102990179 | |
| Person / Time | |
|---|---|
| Site: | Salem, Clinton  |
| Issue date: | 04/28/2010 |
| From: | Eric Bowman Office of Nuclear Reactor Regulation |
| To: | Richard Ennis, Anthony Mcmurtray, Schulten C Office of Nuclear Reactor Regulation |
| References | |
| FOIA/PA-2010-0334, TIA 2010-001 | |
| Download: ML102990179 (4) | |
Text
11
. 1./
En'nis, Rick From: Bowman, Eric I Ncc Sent: Wednesday, April 28, 2010 7:47 AM To: Ennis, Rick; Schulten, Carl; McMurtray, Anthony Cc: Burritt, Arthur; Cline, Leonard; Schroeder, Daniel; Balian, Harry; Conte, Richard; OHara, Timothy; Lupold, Timothy; Tsao, John; Manoly, Kamal; Elliott, Robert; Chernoff, Harold; Nelson, Robert; Giitter, Joseph; Howe, Allen; Honcharik, Michelle; Miller, Barry; Schmidt, Wayne; Cahill, Christopher; Tingen, Steve
Subject:
RE: Summary of 4/27/10 Internal NRC Call on Salem Unit 2 AFW Piping Attachments: ML101100101 .adc
- Rick, We just completed Clinton TIA 2010-001 on the application of SR 3.0.3 to inservice testing at Clinton. I've attached the ADAMS link for it. It might be worth sitting down with Carl Schulten to distinguish the situation here, where the IST requirements are still implemented as surveillance requirements, from the situation at Clinton.
- Carl, I took a really quick look at this; SR 4.0.5.c. at Salem specifically makes SR 4.0.2 applicable to frequencies for IST activities, but there is no mention of SR 4.0.3 applicability to IST activities. Based on our earlier discussions of custom TS implementations of SR 4.0.5, I had thought that both SR 4.0.2 and 4.0.3 would be applicable without the need for their SR 4.0.5.c. I don't plan to pursue this as it hasn't risen to being a TIA, but thought it was a bit odd and wanted to point it out. It also makes me wonder if SR 4.0.1 needs to be specifically implemented for SR 4.0.5.
- Tony, FYI for the implication of IST surveillance requirements in the custom TS.
Thanks!
Eric From: Ennis, Rick /'>riI1 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 C/ 114d
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.
2
- Thanks, Rick 3
Received: from HQCLSTRO1 .nrc.gov ([148.184.44.79]) by TWMS01.nrc.gov
([148.184.200.145]) with mapi; Wed, 28 Apr 2010 07:48:11 -0400 Content-Type: application/ms-tnef; name="winmail.dat" Content-Transfer-Encoding: binary From: "Bowman, Eric" <Eric.Bowman@nrc.gov>
To: "Ennis, Rick" <Rick.Ennis@nrc.gov>, "Schulten, Carl"
<Carl.Schulten@nrc.gov>, "McMurtray, Anthony" <Anthony. McMurtray@nrc.gov>
CC: "Burritt, Arthur" <Arthur.Burritt@nrc.gov>, "Cline, Leonard"
<Leonard.Cline@nrc.gov>, "Schroeder, Daniel" <DanieI.Schroeder@nrc.gov>,
"Balian, Harry" <Harry.Balian@nrc.gov>, "Conte, Richard"
<Richard.Conte@nrc.gov>, "OHara, Timothy" <Timothy.OHara@nrc.gov>, "Lupold, Timothy" <Timothy.Lupold@nrc.gov>, "Tsao, John" <John.Tsao@nrc.gov>,
"Manoly, Kamal" <Kamal.Manoly@nrc.gov>, "Elliott, Robert"
<Robert.Elliott@nrc.gov>, "Chernoff, Harold" <Harold.Chernoff@nrc.gov>,
"Nelson, Robert" <Robert.Nelson@nrc.gov>, "Gitter, Joseph"
<Joseph.Giitter@nrc.gov>, "Howe, Allen" <Allen.Howe@nrc.gov>, "Honcharik, Michelle" <Michelle.Honcharik@nrc.gov>, "Miller, Barry"
<Barry.Miller@nrc.gov>, "Schmidt, Wayne" <Wayne.Schmidt@nrc.gov>, "Cahill, Christopher" <Christopher.Cahill@nrc.gov>, "Tingen, Steve"
<Steve.Tingen@nrc.gov>
Date: Wed, 28 Apr 2010 07:46:59 -0400
Subject:
RE: Summary of 4/27/10 Internal NRC Call on Salem Unit 2 AFW Piping Thread-Topic: Summary of 4/27/10 Internal NRC Call on Salem Unit 2 AFW Piping Thread-Index: AcrmxlqKH188wqHi RaqwfcSB4ZorMAAADlyA Message-ID: <C070F82E831 El C44879BFA258CF960C9193C6C0734@HQCLSTRO1 .nrc.gov>
References:
<9E28710EOB702149AEC6639728636440235CF6DF37@HQCLSTRO1 .nrc.gov>
In-Reply-To: <9E28710EOB702149AEC6639728636440235CF6DF37@HQCLSTRO1 .nrc.gov>
Accept-Language: en-US Content-Language: en-US X-MS-Has-Attach: yes X-MS-Exchange-Organization-SCL: -1 X-MS-TNEF-Correlator:
<C070F82E831 El C44879BFA258CF960C9193C6C0734@HQCLSTRO01. nrc.gov>
MIME-Version: 1.0