Letter Sequence Withdrawal |
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Text
September 29, 2005 Mr. William Levis Senior Vice President & Chief Nuclear Officer PSEG Nuclear LLC - X04 Post Office Box 236 Hancocks Bridge, NJ 08038
SUBJECT:
SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2 -
WITHDRAWAL OF AN AMENDMENT REQUEST (TAC NOS. MC3096 AND MC3097)
Dear Mr. Levis:
By letter dated April 15, 2004, PSEG Nuclear LLC (PSEG) requested amendments to Facility Operating License Nos. DPR-70 and DPR-75 for the Salem Nuclear Generating Station (Salem), Unit Nos. 1 and 2, respectively. Specifically, the amendments would have changed the fire protection program (FPP) to decrease the carbon dioxide (CO2) concentration, hold time, and number of discharges for the fire suppression systems in the 4160-volt switchgear rooms, 460-volt switchgear rooms, and lower electrical penetration area rooms. By letter dated September 26, 2005, PSEG withdrew the amendment request.
In the April 15, 2004, license amendment request, you indicated that the fire suppression system does not provide the CO2 concentration specified in the current licensing basis. The current licensing basis CO2 concentration is 50% with a hold time of 30 minutes. The proposed changes would require a CO2 concentration of at least 27.6%, a hold time sufficient to allow the PSEG fire department to respond, and sufficient capacity for one full discharge plus an additional partial discharge to be used at the discretion of the responding PSEG fire department. Your April 15, 2004, letter states that PSEG evaluated the lower CO2 concentration considering the types and species of combustible materials that are located in these rooms and concluded that sufficient CO2 is available to suppress fires and allow the on-site PSEG fire department to respond and take proper action.
The Nuclear Regulatory Commission (NRC) staff has conducted a careful review of the information in your April 15, 2004, application. The staff also visited Salem on March 4, 2005, as part of its review. The staff has concluded that the ability of Salem to achieve and maintain a safe shutdown in accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Appendix R, may be adversely affected by the proposed change for the following reasons:
- Safe-shutdown equipment in these rooms is not separated by complete one-hour fire-rated barriers. Salem has received exemptions to Section III.G.2 of Appendix R to 10 CFR Part 50 to address this issue. The NRC staff approved these exemptions, in part, because these rooms were protected by a CO2 system that had a design concentration of 50% and a hold time of 30 minutes.
The April 15, 2004, letter implies that some of these exemptions may not be needed due to plant modifications, but the status of the exemptions is not clear.
W. Levis
- The design concentration of CO2 in these rooms cannot be met, in part, because the CO2 is migrating into adjacent areas of the plant. This was identified in Event Notification No. 41359, dated January 26, 2005. Some of these adjacent areas are required to be accessible by operators to perform manual actions to achieve and maintain safe shutdown.
- The National Fire Protection Association (NFPA) Standard NFPA 12, Standard on Carbon Dioxide Extinguishing Systems, 1968 Edition, which is the code of record for the Salem CO2 system, specifies a minimum CO2 concentration of 50% for deep-seated fires. Also, later editions of NFPA 12 specify a minimum CO2 concentration of 34% for surface fires.
- The information that PSEG provided to support the lower concentration of CO2 is insufficient for the staff to conclude that a fire can be suppressed or extinguished in a reliable manner with the proposed change in place.
The staff notes that, as discussed in Event Notification No. 41359, dated January 26, 2005, related to CO2 migration, PSEG has implemented compensatory measures to address the issues with the CO2 fire protection system. This action is consistent with the Salem FPP when non-conforming conditions are identified. In accordance with the Salem FPP, the compensatory measures should remain in place while prompt corrective actions are taken.
Your September 26, 2005, letter stated that PSEG would like to continue discussions with the NRC staff on the proposed resolution of issues related to migration and system degradation.
The staff supports your efforts in this regard. The staff would like to meet and discuss these issues within 30 days of receipt of this letter. At the meeting, please be prepared to discuss the status of the Salem FPP (i.e., the status of Appendix R exemptions, the causes of reduced CO2 concentration, the effects of CO2 migration, etc.) and your plans to return the Salem FPP to conformance with its licensing basis. Please contact me to set up the discussions. I can be reached at (301) 415-1321 or by e-mail at snb@nrc.gov.
Sincerely,
/RA/
Stewart N. Bailey, Sr. Project Manager, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-272 and 50-311 cc: See next page
ML052710083 OFFICE PDI-2/PM PDI-2/LA SPLB/SC PDI-2/SC NAME SBailey CRaynor SWeerakkody DRoberts DATE 9/29/05 9/28/05 9/29/05 9/29/05 Salem Nuclear Generating Station, Unit Nos. 1 and 2 cc:
Mr. Michael Gallagher Dr. Jill Lipoti, Asst. Director Vice President - Eng/Tech Support Radiation Protection Programs PSEG Nuclear NJ Department of Environmental P.O. Box 236 Protection and Energy Hancocks Bridge, NJ 08038 CN 415 Trenton, NJ 08625-0415 Mr. Dennis Winchester Vice President - Nuclear Assessment Mr. Brian Beam PSEG Nuclear Board of Public Utilities P.O. Box 236 2 Gateway Center, Tenth Floor Hancocks Bridge, NJ 08038 Newark, NJ 07102 Mr. Thomas P. Joyce Regional Administrator, Region I Site Vice President - Salem U.S. Nuclear Regulatory Commission PSEG Nuclear 475 Allendale Road P.O. Box 236 King of Prussia, PA 19406 Hancocks Bridge, NJ 08038 Senior Resident Inspector Mr. Darin Benyak Salem Nuclear Generating Station Director - Regulatory Assurance U.S. Nuclear Regulatory Commission PSEG Nuclear - N21 Drawer 0509 P.O. Box 236 Hancocks Bridge, NJ 08038 Hancocks Bridge, NJ 08038 Mr. Carl J. Fricker Mr. George H. Gellrich Plant Manager Plant Support Manager PSEG Nuclear - N21 PSEG Nuclear P.O. Box 236 P.O. Box 236 Hancocks Bridge, NJ 08038 Hancocks Bridge, NJ 08038 Jeffrie J. Keenan, Esquire PSEG Nuclear - N21 P.O. Box 236 Hancocks Bridge, NJ 08038 Lower Alloways Creek Township c/o Mary O. Henderson, Clerk Municipal Building, P.O. Box 157 Hancocks Bridge, NJ 08038
