ML17054B348
| ML17054B348 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 01/18/1985 |
| From: | Schwencer A Office of Nuclear Reactor Regulation |
| To: | Hooten B NIAGARA MOHAWK POWER CORP. |
| References | |
| GL-84-08, GL-84-8, NUDOCS 8501300109 | |
| Download: ML17054B348 (12) | |
Text
~P5 AEGIj~
~G>
p.
+
0 Cy A.o C
O I
n +a*++
Docket No. 50-410 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 JAN 18 ]98g Mr. B. G. Hooten, Executive Director, Nuclear Operations Niagara Mohawk Power Corporation 300 Erie Boulevard West
- Syracuse, New York 13202
Dear Mr. Hooten:
SUBJECT:
AIR DRYERS IN THE DIVISION 1 AND 2 DIESEL GENERATOR AIR START SYSTEMS In our letter to you on October 17, 1984 we identified the NRC staff technical basis f'r our position that air dryers be used for the Division 1 and 2 diesel generator air star t systems at Nine Mile Point 2.
1 In a meeting on October 23, 1984, Mr. A. Zallnick of your staff stated that NMPC considers this position constitutes a backfit.
In our letter of November 15, 1984 we noted that you have the right to appeal an issue you consider a backfit and directed you to the appeal process described in Generic Letter 84-08 "Interim Procedures for NRC Management of Plant - Specific Backfitting" which was sent to you on April 4, 1984.
In a letter dated November 19, 1984 from Mr. C. V. Mangan of your staff you stated that the position that air dryers be used "appears" to impose a backfit.
You further stated that Niagara Mohawk could not determine if you wished to appeal this issue and requested the following information:
1) performance and qualification requirements for the diesel generator air starting system 2) the priority of the backfit implementation for this issue 3) the regulatory requirement for this issue 4) how backfits are to be handled in the SER 5) why this issue is not being handled on a generic basis As discussed in NUREG/CR-0660, air dryers should have a performance dewpoint no less than 10'F lower than the lowest ambient temperature.
Air dryers should also be filtered to the vendor's requirements.
Desicant air dryers such as used at River Bend or on the NMP-2 HPCS diesel generator are acceptable 00109 850ii8 OCK 05000410 PDR AD A
I s
~
to the staff.
Air dryers do not need to be safety-grade but should be installed prior to pre-op testing and be tested as part of the diesel generator system.
As stated in our October 17, 1984 letter the acceptance criteria in SRP 9.5.6 (NUREG-0800) states that each diesel generator air starting system should include air dryers.
As stated in Enclosure I to Generic Letter 84-08 (Draft Manual Chapter 0514, NRC Program for Management of Plant-Specific Backfitting of Operating Power Plants), backfitting occurs when the NRC staff takes a
new position or changes its interpretation of an existing position.
The inclusion of air dryers in the diesel qenerator air start system is neither a
new position nor a change in the staff's interpretation of SRP Section 9.5.6, therefore the staff has not identified this issue as a backfit issue.
Consequently, no backfit priority has been assigned to this issue.
- However, as stated in our letter of November 15, 1984 you do have the right to appeal this staff position.
As noted in SRP Section 9.5.6 the use of air dryers in the diesel generator air dryers is part of the specific criteria and guidance necessary to meet the relevant requirements of GDC 17 (10 CFR 50, Appendix A).
The NRC staff has reviewed NMP-2's alternate proposal of the use of moisture separators and filters, in conjunction with manual blowdown of the air receivers and system piping.
The staff's basis for considering this proposal inadequate is discussed in detail in our October 17, 1984 letter.
Other alternatives to the air dryers are the use of dry and clear "instrument quality" air (as discussed in the October 17, 1984 letter) or the elimination of all ferrous metal in contact with air with some system for moisture reduction (Limerick).
A proposal to use either of these alternatives would require review by the staff of the proposed alternative as applied to NMP-2.
Issues which have not been resolved at the time a Safety Evaluation Report (SER) is issued are identified as outstanding issues.
This procedure will be followed here with a notation that the item has been identified as a backfit by the applicant and that the applicant is considering an appeal to the staff's position.
Finally, the need for air dryers for the diesel generator air start system was reviewed generically as part of the development of the SRP (NUREG-0800).
- However, plant specific applications of these dryers are reviewed as part of the OL review on a plant specific basis.
As stated above and in our letter of November 15, 1984, you have the option of appealing this issue through the backfit appeal process described in Generic Letter 84-08.
If you do intend to appeal this issue you should notify, in writing, Mr. Darrell G. Eisenhut, Director, Division of Licensing of'our desire for an appeal meeting with the staff.
The appeal should contain a clear statement of your position along with supporting justification.
Me have attempted to respond to the concerns in your November 19, 1984 letter in order to facilitate your decision of whether to appeal the use of air dryers in the diesel generator air start system.
If you have any further questions
~
t
~
~
l please contact the licensing project manager, Nary F.
Haughey at (301) 492-7897.
Sincerely, A. Schwencer, Chief Licensing Branch No.
2 Division of Licensing See next page
~
e
~
t'
Nine Mile Point 2
Mr. B. G. Hooten Executive Director, Nuclear Operations Niagara Mohawk Power Corporation 300 Erie Boulevard West
- Syracuse, New York 13202 CC:
Mr. Troy B. Conner, Jr.,
Esq.
Conner 8 Wetterhahn Suite 1050 1747 Pennsylvania
- Avenue, N.W.
Washington, D.C.
20006 Richard Goldsmith Syracuse University College of Law E. I. White Hall Campus
- Syracuse, New York 12223 Ezra I. Bialik Assistant Attorney General Environmental Protection Bureau New York State Department of Law 2 World Trade Center New York, New York 10047 Resident Inspector Nine Mile Point Nuclear Power Station P. 0.
Box 99
- Lycoming, New York 13093 Mr. John W. Keib, Esq.
Niagara Mohawk Power Corporation 300 Erie Boulevard West
- Syracuse, New York 13202 Jay M. Gutierrez, Esq.
U. S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Pennsylvania 19406 Norman Rademacher, Licensing Niagara Mohawk Power Corporation 300 Erie Boulevard West
- Syracuse, New York 13202
~
~
please contact the licensing project manager, Mary F. Haughey at (301) 492-7897.
Sincerely, A. Schwencer, Chief Licensing Branch No.
2 Division of Licensing cc:,'ee next, page Distribution:
~F NRC PDR Local PDR PRC System NSIC LB82 Reading EHylton MHaughey Bordenick, OELD ACRS (16)
EJordan NGrace P. Trembly E. l4einkam E. Tomlinson A. Ungaro
- See previous concurrence
- LB82/DL/PM
- PSB/CPS/BC MHaughey/lb MSrinivasan 01/08/85 01/09/85 LB8 /DL/BC ASchwencer 01/g /85
~
t II 0 )
-y gH II
('I<~'I q'll 4'p
'~" fl(
N
'h ~
'1 please contact the licensing project manager, Mary F. Haughey at (301) 492-7897.
Sincerely, A. Schwencer, Chief Licensing Branch No.
2 Division of Licensing cc:
See next page Distribution:
NRC PDR Local PDR PRC System NSIC LB¹2 Reading EHylton MHaughey Bordenick, OELD ACRS (16)
EJordan NGrace P. Trembly E.
Weinkam E. Tomlinson A. Ungaro
- See previous concurrence
- LB¹2/DL/PM MHaughey/lb 01/08/85
- PSB/CPS/BC MSrinivasan 01/09/85 LB¹ /DL/BC ASchwencer 01/if/85
I,