ML102980135

E-Mail from Defrancisco to Ambrosini, Enforcement for Oc Finding

ML102980135
Person / Time
Site:	Salem
Issue date:	07/21/2010
From:	Anne Defrancisco NRC Region 1
To:	Josephine Ambrosini, Jeffrey Kulp NRC/RGN-I/DRP/PB6
References
FOIA/PA-2010-0334
Download: ML102980135 (3)

Text

From: DeFrancisco, Anne Sent: Wednesday, July 21, 2010 8:20:37 AM To: Ambrosini, Josephine; Kulp, Jeffrey Cc: RiENFORCEMENT RESOURCE; Barber, Scott

Subject:

Enforcement for OC Finding Auto forwarded by a Rule PRELIMINARY DRAFT INFORMATION - DO NOT RELEASE Jo, Jeff: Below is an excerpt from a marked up draft quarterly feeder for Salem dealing with a failure to meet 50.55a for a degraded piping issue. Question - I see in your OC writeup that the licensee did some calcs and acoustic testing for the core spray check valve -

what is the status of their overall operability assessment? -Anne Finding The inspector identified the following violation related to ASME,Section XI testing of buried Unit 1 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 X1, 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 ýPortions of the Unit 1 and Unit'2 Auxiliary Feedwater (AFW) System piping is buried piping and has not been visually inspected since th e plant began 6peratio6 in 1977 for Unit 1 and since_1979for Salem Unit 2. InApri. 20f,_0 approximately.'680 ft. (340 ft.fof the #12 SG AFW supply and 340 ft. of the'#14 SG AFW supply) of piping betweeInthe purmp discharge manifodld and the connection tbthe Maini Feedwater piping to the.'affectedSGs was discoveredt o'be corroded to below~mlnimurn'wa'I1thickniess (0.278") for t'he195'0 ,si design pres r f~the AFW S sten*i' The lowest wall thickness measured in the affeced pipig was 6.077",. (b)(5)

(b)(5).. ( )5 10 CFR SO.S5(a)(g)(4)(ii) requires licensees to follow the in-service requirements of the ASME Code, Section X1.Paragraph IWA-5244 requires licensees to perform pressure tests on buried components to demonstrate structural integrity of the tested piping. The pressur by IWA-5244 is considered to be an inservice inspection and is part of Section XI.

(b)(5) k f mt* I n# Wr c ord I M*CI Oted i n 1="W~th the Fre--toM of l.nfoatMMn A0t FOLWA

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, PSEG did not perform the proposed alternate tests during the 2 "dinservice I (b)(5) interval and during the 1" (5/19/01 t-'(b/5 r

X-*---*? ..

In~n~tinn Intprval for. Unit I

I I (b)(5)()5 hus, PSEG missed an opportunity to identify and correct this performance deficiency (b)5)hic afets Uni 11and Unit 2.

PSEG repiaced the affected buried Unit 1 piping during the refueling outage in April/May 2010.

The required completed after the replacement of the Unit 1 tests were successfullyIresure I (i5in).11(b)(5)

(buri)d l(b)(5)

(b)(5)

The inspector determined that a Cross Cutting Aspect did not exist because the issue was not Indicative of current performance because the condition existed since 1991, more than 3 years ago. Specifically.. .

Enforcement 10 CFR 50.55a(g)(4) states, in part: "Throughout the service life of a boiling or pressurized water-cooled nuclear power facility, components which are classified as ASME Code Class 1, Class 2 and Class 3 must meet the requirements,... , set forth in Section Xlof editions of the ASME Boiler and Pressure Vessel Code". ParagraphIWA-5244, Buried Components, of Section Xlsays, in part,

"(b) For buried components where a VT-2 visual examination cannot be performed, the examination requirement is satisfied by the following: (1) The system pressure test for buried components that are isolable by means of valves shall consist of a test that determines the rate of pressure loss. Alternatively, the test may determine the change in flow between the ends of the buried components..."

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 2 d In Service Inspection Interval (2/27/88 to 5/19/01) and during the 1" (5/19/01 to 6/3/04a "2Mi6/24/04 t q/0 t(b)(6) ,

I/

Because PSEG entered this condition into the corrective action process (Notification 20459686) and because it 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-??

PRE*CIMINAR-Y-DFAF-T-tN IrO-RMATION - T-%R.T"ASE

/'fice oflthe ReionIdminiis, tnr. ReJ.iwt /

6/10-33 7-5( 78 anne.defrancisco&-nrc.gov