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
n/9 "(1WL-
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
475 ALLENDALE ROAD
KING OF PRUSSIA, PA 19406-1415
July 22, 2010
MEMORANDUM TO: Arthur L. Burritt, Chief
Projects Branch 3
Division of Reactor Projects
THRU: Richard J. Conte, Chief
Engineering Branch I
Division of Reactor Safety
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.
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2
No specific 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 r~
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 inan 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 w
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."
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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 :',,. ,'
Policy.
Follow up Comments for Future PI&R Sample
Because PSEG had not completed 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.
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.... . 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 *6!6,'6:
system to protect the piping from degradation/corrosion for the design life of the plant. *,'.67'66
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 *-6
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........ '66664.' i,666 6
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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
4 ~4 '>4
DRS Files ~44~ ~
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SUNSI Review Complete: TLOIRJC (Reviewer's Initials) +:++:
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Non-Public Designation Category: MD 3.4 Non-Public A.7 +++*+*:+*;+;? '>4+
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. +++++++++>'
- +;*+;++ .++ +++ i +A
To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with
++::++
- +.+... . + /',
+* .. .+ . ,+ + ,
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 ,
- ,?+,+
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- +*+;* +
- +++++.,+ .4,
OFFICIAL RECORD COPY
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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,
este~s
t~y on~ undppn opnnsa required by. 10 CFR 5O.55a(g)(4) and the
red nericaS~n~ Megchanica['Engineers Cod (S~)
of~t~ Section Xi 'paragra2h.
fo j6 Unitae 2. The reqiJiredtr'6sts are in endd o _
4 I"M 'Tcmi
ndqie ~ t1e9,1
peafce piri is sa-f ielated, MEClas's 3, i~cCIa 0OpIpingrfhiL visent"naie~P
erf, ace efiiency is mr e than minor becaue the con~dition affected the EfqLýOet~
_s ofneanute ~(availabilit and rlaityof te mitigating ssei~biesoe
~jecbve ~ ~'K
W M 'g,
-Wa.m. on St rat R-stru 3M=V IIRA AKAGý he "Ann
-fe r-'af46Un
1144Wit 2 ni Ot mlsivol
- 'i-n
6081016, hodicati, f 1t_*Tdý
Pfoht his finding is described in
Section 1R08.
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 j ~,
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 ~
~-4, ~
,~.d, ~
The inspectors reviewed a sample of the Unit 1 steam generator eddy current testing . ~-. ,,
~.,
V .
~.*,,s ~
(ECT) tube examinations, and applicable procedures for monitoring degradation of
steam generator 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 in the SG ECT inspections during the 1R20 refueling outage.
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 past operability 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
- i4porbtons 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 on the #11 SG Feedwater 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 et0u
]*H*underslarld th'at {th* re, arrS
retoVlf~r**, - ms 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;'
e*upked.e
existence of structural integrity. - t n uirei 3e IftEfm cbsser ° cnsayP.l
- .enoure~y~*}ioprssuryeth*o s * u
3tpeln.k 6 , ; MOeti~
- n d__ *;**:
'per" Inera
=° * * '; * 1.L' PSEG
Thus 4 ... (comnlent[L"6]:*Slhouid -lt~slog~*
j 4did not to perform the only inservice inspection, intended to ' "*. . .. *..
efdemonstrate the structural integrity of this safety related buried piping. * .,.i[],'*!*
testAung~h~2visericen~aari~
du~n~ the~ (i1901~o~6//04an&P.
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, *SEG t-ttet se*r~opisetl
!;A)-4.4.the 9l In Service insp J
cinIntenddvoamide 1Phuse
P SEG in7ciue
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t
Enfareen
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misse&~9pp___ ____ I~reR¶i, ~cA~r t
~§fi~en~y which~ff&6t~.
rw 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
buried piping. Because the AFW
the Unit8142Ilito system functioned as did required during the
plant shutdown prior to the start of, 1R20 p~er (April 2010),ctthe system ikA not looseh?6fo
operability.
PSGretlaed 6~~t6iTtlthe afe~ctd buredu let1piigdurteing otaehereueing fortag
inArihg/2May
d
th Uit brid i pngng. Becraus cyth
ea sysem fu ctioe .as eqire odirionga the
Analysis.The reqired pre t r were
fore qucrdssfullycom af e replat
tlieted
perform the only inservice inspection (IWA-5244), intended to provide-eviden o ,
demonstrate the structural integrity of this safety related buried piping. wasiurther
Ljniii Y
rOsultodpininm a eroreniianc codeition ducrtoac tined
aen undtcctedcroion wasthou
pr ftrt15or fo ilr ete.rckatterýg e iirrelcesti'g'f1 F
permabilityfyheat repova
c
Thes oninetion
[1¶& ascreened th
inl ectbr menperformance
d attinbyutesvin abiMC
"3Vf ity9
Atacdhmenibltyo
imat he m~i~tigat Cirnersstemorners~tine tyodvesu'tel afetn h ecnay hr
tem ecy etre~movle*lt: ata, o**ng td,,*~x*~c sf*
EGCeq uestedghr
Sandtiee ** m a
..fi Lr,* !je W
tionssf * g - .ecte.. . .. .n . .. .. .. . .
&ac .
5
Enforcement. 11hbatte srv61
=r~
LqsrzdwtrýrAed ula oi6'T f~ilitcomiponents ihare!
cIassifiedasVASME 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 valvesý
shai~onsstof 1st thatV ~detris thdýrtepressttr. loss. Atrilati!yel t~
1ýt--i rh -iowf1- ftký*,
c pm_,fj2t-s.
"I -------------------------- ~~d~o
tha 1 l~t~
0t eo'e6hae
Contrary to these requirements, PSEG did not perform the required pressure tests of the 'rcMmendddetj~ addressF
my
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 f*llowing finding of very l.w safcy was identified by PSEG. The finding
.igifi.a...
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 psiortogt~i
r A'1so rhai
w~ s te~illltsmtgatn f
short ermadecay heat removal.capability.The__na__gwas__emlet6be Green_
Ioss of.operabli ty* 661RY,* -o .".
ON .I.-.--
.I.-
- .-.--
7
Because PSEG entered this condition into the corrective action process (Notification 4;
- , ..
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
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A-1
ATTACHMENT
SUPPLEMENTAL INFORMATION
KEY CONTACTS
Licensee Personnel: '4
Howard Berrick, PSEG ~: ~
Pat Fabian, PSEG
Mohammad Ahmed, PSEG
Tony Oliveri, PSEG
Tom Roberts, PSEG
Ali Fakhar, PSEG
Len Rajkowski, PSEG
Dave Mora, PSEG 44"
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
LIST OF DOCUMENTS REVIEWED i 4~ AV '~<
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
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.*
flt.< *> y(. *t.. -
A-2
20459259, Ul Corrosion on Containment Liner* (4 ~ ~4W~'i
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
4 4w~'
20290560, Replace section of 15B FWH shell-S1-R18
20457879, (184) 1R20 FAC(N18) 14# elbow below Tmin '.44,
20456828, (66) valve has visible boron buildup 1R20
20459232, Heavy Dry White Boron VIv Packing (1R20)
20456834, Heavy Dry White Boron VIv Packing (1 R20)
20456840, Medium Dry White Boron VIv Packing (1R20)
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 A'
20444514, Boric Acid Leak from Drain Line - PI&R review
20445314, boron leak - PI&R review ((9,
20448241, Minor Packing Leak - BAC - PI&R review 4'.
'> .
20435861, 21SJ313 Has Boric Acid Leakage - PI&R review ~44944
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 ~ ~' 4,
20438320, (217) Op Eval. Of Containment Corrosion - PI&R review 4 ".4
20387897, Significant outlet pipe corrosion - PI&R review 4<,
444~'..~4
20397225, MIC Corrosion Causing Through Wall Leak - PI&R review
20436836, Repair Cracks in Battery Cells - PI&R review
~44( (~,
20392145, Update U1 ISI Relief Request Book - PI&R review "-'4
4 44
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 4 .4'
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 4,4 4~
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,
4'4'
C"
A-3
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 * <'1'
20389147, Recordable ISI Indications on CVC Tank - PI&R review
Y1A~i
20392145, Update Ul ISI Relief Request Book - PI&R review ~
~4~< ~'4', ~
~" '1
20449744, Update Salem U1 Containment ISI 10 Yr. Plan - PI&R review &Žr~
20409943, NRC RIS 2009-04 SG Tube Insp Rqmts - PI&R review ~; '4h:;;
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 Y~ >~k"~1/2
- Denotes this Notification was generated as a result of this inspection
Section XI Repair/Replacement Samples:
& >.& '
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 '&4<4,.-
W.O. 60084375, BACC Program repair to 1PS1
W.O. 60089612, BACC Program repair to SlCVC-14CV392 7
W.O. 60089615, BACC Program repair to S1SJ-13SJ25 <~4< 4~' 4~ -
W.O. 60089848, 80101382 Advanced Work Authorization #2 FTTA Replace Aux. Feedwater
Pipe V ,~
W.O. 60089561, 80101381 Advanced Work Authorization - Replace Aux. FW U/G Piping,
4/9/10
Non-Code Repair
.~4 ,4
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 , ,,',."
7
Miscellaneous Work Orders:
W.O. 60089917, Penetrations for CA & SA Lines, 4/23/10 I
W.O. 941017262, Activity 04, Excavate and Examine Auxiliary Feedwater Piping, Unit 2, 12/94 ~ 4 ~'
W.O. 941017262, Activity 03, Excavate and Examine Auxiliary Feedwater Piping, Unit 2, 12/94
W.O. 941017262, Activity 02, Excavate and Examine Auxiliary Feedwater Piping, Unit 2, 12/94
W.O. 941017262, Activity 01, Excavate and Examine Auxiliary Feedwater Piping, Unit 2, 12/94
W.O. 60089561, Flush New AFW piping 12 and 14
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 C""
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
~,~K:
A-4
207483A8923-28, Sheet I of 4, Salem Nuclear Generating Station, Unit No. 1 - Reactor Y
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 Penetration
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
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), ~t
Revision 2, Integrated Strategic Plan For Long Term Protection from Primary Water
Stress Corrosion Cracking (PWSCC), 10/15/09 r
ASME, Section X1,1998 Edition, 2000 Addenda, IWA-5244 Buried Components
OAR-i, Owner's Activity Report, #S1RFO19, 1/15/09
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 ~r
>~
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 rJ~ ~;
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, 9
Revision 6
PSEG Test Procedure 10-H-8-R1, Unit 2 Auxiliary Feedwater 2100/2150 Hydro; 9/21/78 ~ ~ j
NDE Examination Reports & Data Sheets
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%) 2
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 T~
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 <A
2
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 Feedwater Piping,
12/2/94
W.O. 60084266, UT Unit 1 AFW (thinnest area), 4/20/10 4,
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 41-
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
4- ,
VT-2, Salem Unit 1 AF 12 & 14 Pressure Test, 4/25/10 >2
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
41
A-7
Eddy Current Testing Personnel Qualification Records
A2421 C2028 R6452 T5616
88731 C4596 R8002 R931 1
80500 C3340 S7752 G4943
B5127 D3858 T8251 C5542
B5128 H6267 V3197 F0075
B2576 H0282 R4142 F6623
F3961 14048 R6279 F3453
C1560 J1978 G3380 G4943
D7895 2010983302133 83720 G1311
D9573 P6459 R6900 H7791
22 4
D6502 R0830 A9608 J9141
H2039 Ri1164 N2574 M0950 4~ 24f2~2 2
2~
K5380 S0608 13805 M2665
M9460 2509981330193 .T2170 M7006 '222.2 2244
E0427 K5858 N4815 M9459 22 2 22 2222~
M6664 1007951330114 M0945 M7007 2'. %.22~
'22' '1 22~.2222,
84260 L9168 P2963 M9082 2224222
24222~22. 222 '2
~ ~2~2
2222.~&~
A3502 L4332 M9715 N7035
J9815 F7460 K1 903 N9952 '24~'
P5436 F0037 D5318 R9311I 2~2~
M6042 317943330158 W6070 S9098 >222422222' 222'~K2~2~" >2
B8589 6206070744 M5096 T5616
~22&142
22,1222 ~2'~212222,1
84014 6507061922 J1945 T5565 22
2 '2'222 22
2222 2' 2222224 ~ 2' 224224222242
G2573 1803983330125 L4588 W2639 2.242,2
~ S
V8530 2709977301226 C8042 W7912 2 ~ 4
W3368 P5304 N5330 K>
M4305 P4006 L8267 422 74222242. ~ ~ 2
2222>'
222
242.
84052 R4201 F3453 ~4. 242~ '4- '2
24442422242
K6975 242 '722' 22
,2222~ .4.
G391 0
H0268 2222~722 24'""
22
L3025
P1465 2 2.2
B8079 42
G1756 2, 22<2 *2
C8071
6410058746
B5371
H2131
2909965330076
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 Feedwater 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 4 .
Assessment For Cycles 19 and 20, 10/30/07 ~
701086998-0050, Maximum Pressure in Underground Auxiliary Feedwater Piping
60089575-130, Past Operability Determination for the leak in the one inch air line to air operated 4
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 Feedwater 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 Feedwater 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
- .,. <AZ. -
Y..
.7w.
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
I,
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
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 v4~ 4
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 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 Feedwater 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 American Society of Mechanical Engineers
BAST Boric Acid Storage Tank
CEA Control Element Assembly
CEDM Control Element Drive Mechanism
CFR Code of Federal Regulations
EDG Emergency Diesel Generator
EPRI Electric Power Research institute
EQ;ACE Equipment Apparent Cause Evaluation
EQ Environmental Qualification
ER Engineering Request Ky
FTTA Fuel Transfer Tube Area ~
IMC Inspection Manual Chapter
IP Inspection Procedure
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IR NRC Inspection Report
LER Licensee Event Report
LOCA Loss of Coolant Accident
MT Magnetic Particle Testing
MSIP Mechanical Stress Improvement Process K?"
NCV Non-cited Violation K ~"
Notification Corrective Action Notification
NRC Nuclear Regulatory Commission K k'-
NDE Nondestructive Examination
OE Operating Experience
PDI Performance Demonstration Initiative
PI&R Problem Identification and Resolution
PSEG Public Service Electric & Gas, LLC
PWSCC Primary Water Stress Corrosion Cracking
PQR Procedure Qualification Record (Welding Procedures)
RT Radiographic Test (Radiography)
PT Dye Penetrant Testing
SDP Significance Determination Process
SE Safety Evaluation
A-12
SI Stress Improvement
SSC Structure, System, and Component
TS Technical Specifications
UT Ultrasonic Test fl~
UFSAR Updated Final Safety Analysis Report
VT Visual Examination
WPS Weld Procedure Specification
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A-13
INSPECTION SAMPLE COMPLETION STATUS
4'
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) $~~$*4~$4> 4
Biennial (B)
7111108 (G) 1 Y
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2515/172 1 YES
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Attachment B-1
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TI 172 MSIP Documentation Questions Salem Unit I
Introduction:
The Temporary Instruction (TI), 2515/172 provides for confirmation that owners of
I ~
pressurized-water reactors (PWRs) have implemented the industry guidelines of the 'A
Materials Reliability Program (MRP) -139 regarding nondestructive examination and
evaluation of certain dissimilar metal welds in the RCS containing nickel based Alloys ~fr ~
V.
600/82/182. This TI requires documentation of specific questions in an inspection report.
The questions and responses for MSIP for the IR 05000311/2009005 section 40A5 are
included in this Attachment "B-i".
In summary the Salem Units 1 and 2 have MRP-139 applicable Alloy 600/82/182 RCS
welds in the four hot and four cold leg piping to reactor pressure vessel nozzle
connections for each plant. -'A: &V,,
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For Unit 1 during the 1R20 refueling outage in April 2010 PSEG inspected one dissimilar metal 'A 'A'
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'weld, a SG channel head drain line weld. No indications were reported from this inspection.
PSEG plans on replacing this valve, and the dissimilar metal weld, during refueling outage
1 R22. ~A~$"
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TI 2515/172 reauires the followina a uestions to be answered for MRP-139 MSIP inspections:
Question 1: For each mechanical stress improvement used by the licensee during the Salem U1
1R20 outage, was the activity performed in accordance with a documented qualification report """V ~K$~2':~"A"'~
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 1R20.
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 5'
report?
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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.
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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.
Needs to address all the
This does not meet the MC 0612 documentation requirements.
be something like this. The inspectors
screening criteria. A more appropriate statement would
(Green) because the finding was not a
determined the issue was of very low safety significance loss of safety function, and was not
design or qualification deficiency, did not result in an actual
potentially risk significant for external events.