ML17158B049
| ML17158B049 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 12/06/1995 |
| From: | Poslusny C NRC (Affiliation Not Assigned) |
| To: | Byram R PENNSYLVANIA POWER & LIGHT CO. |
| References | |
| TAC-M84770, TAC-M84771, TAC-M90600, TAC-M90601, NUDOCS 9512120387 | |
| Download: ML17158B049 (6) | |
Text
Mr. Robert G.
Byram ~
Senior Vice President~iclear
.Penh~ylvania Power and Light Company 2 North Ninth Street Allentown, PA 18101 December 1995
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION UPCOMING MEETING REGARDING THE FIRE PROTECTION PROGRAMS AND SAFE SHUTDOWN CAPABILITY FOR THE SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 and 2
(TAC NOS.
- H84770, H84771, H90600 AND M90601)
Dear Hr. Byram:
On August 29,
- 1995, NRC staff and a contractor from Brookhaven National Laboratory (BNL) met with Pennsylvania Power 8 Light Company (PPEL) representatives to discuss the safe shutdown analysis for the Susquehanna Steam Electric Station (SSES)
Units 1
8 2 and a previously submitted request for exemption from Appendix R related to control room hot shorts.
Our BNL reviewer has identified some additional issues which need to be addressed or clarified in order to reach conclusions on the adequacy of the safe shutdown analysis and the justification for an exemption from Appendix R.
I have enclosed a request for additional information on Revision 4 of the PP8L Fire Protection Review Report and PP8L Calculation EC-013-0859, "Appendix R
Safe Shutdown Analysis for a Control Room Fire," Revision 1.
The level of detail included in the enclosure require that a face to face meeting be conducted to ensure that the NRC fully understands PPKL's fire protection programs and strategy for safe shutdown.
Accordingly, please have your staff review this document and be prepared to provide responses and comments during the next meeting with the NRC and BNL staff.
We and our contractor are prepared to meet with your staff at your earliest convenience at your Allentown office or at the SSES site.
Please have your staff contact me with a proposed date for this meeting.
This requirement affects nine or fewer respondents and, therefore, is not subject to the Office of Management and Budget review under P.L.96-511.
9'Si2%20387 95i20b PDR ADQCK 05000387 F
PDR Docket Nos.
50-387/388 Sincerely,
/S/
Chester
- Poslusny, Senior Project Manager Project Directorate I-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation
Enclosure:
Request for Additional Information cc w/encl:
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Hr. Robert G. Byram Senior Vice President-Nuclear Pennsylvania Power and Light Company 2 North Ninth Street Allentown, PA 18101 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON> D.C. 20555-0001 December 6,
1995
SUBJECT:
RE(VEST FOR ADDITIONAL INFORMATION UPCOMING MEETING REGARDING THE FIRE PROTECTION PROGRAMS AND SAFE SHUTDOWN CAPABILITY FOR THE SUS(UEHANNA STEAM ELECTRIC STATION, UNITS 1 and 2
(TAC NOS.
- H84770, H84771, H90600 AND H90601)
Dear Mr.
Byram:
On August 29,
- 1995, NRC staff and a contractor from Brookhaven National Laboratory (BNL) met with Pennsylvania Power
& Light Company (PP&L) representatives to discuss the safe shutdown analysis for the. Susquehanna Steam Electric Station (SSES) Units 1
& 2 and a previously submitted request for exemption from Appendix R related to control room hot shorts.
Our BNL reviewer has identified some additional issues which need to be addressed or clarified in order to reach conclusions on the adequacy of the safe shutdown analysis and the justification for an exemption from Appendix R.
The level of detail included in the enclosure require.that a face to face meeting be conducted to ensure that the NRC fully understands PP&L's fire protection programs and strategy for safe shutdown.
Accordingly, please have your staff review this document and be prepared to provide responses and comments during the next meeting with the NRC and BNL staff.
We and our contractor are prepared to meet with your staff at your earliest convenience at your Allentown office or at the SSES site.
Please have your staff contact me with a proposed date for this meeting.
This requirement affects nine or fewer respondents and, therefore, is not subject to the Office of Management and Budget review under P.L.96-511.
Sincerely, 9 ~0~
Chester
- Poslusny, Senior Project Manager Project Directorate I-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket Nos. 50-387/388
Enclosure:
Request for Additional Information I have enclosed a request for additional information on Revision 4 of the PP&L Fire Protection Review Report and PP&L Calculation EC-013-0859, "Appendix R
Safe Shutdown Analysis for a Control Room Fire," Revision 1.
cc w/encl:
See next page
gr. Robert G.
Byram Pennsylvania Power
& Light Company Susquehanna Steam Electric Station, Units 1
& 2 CC:
Jay Silberg, Esq.
- Shaw, Pittman, Potts
& Trowbridge 2300 N Street N.W.
Washington, D.C.
20037 Bryan A. Snapp, Esq.
Assistant Corporate Counsel Pennsylvania Power
& Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Mr. J.
M. Kenny Licensing Group Supervisor Pennsylvania Power
& Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Mrs. Maitri Banerjee Senior Resident Inspector U. S. Nuclear Regulatory Commission P.O.
Box 35 Berwick, Pennsylvania 18603-0035 Mr. William P. Dornsife, Director Bureau of Radiation Protection Pennsylvania Department of Environmental Resources P. 0.
Box 8469 Harrisburg, Pennsylvania 17105-8469 Mr. Jesse C. Tilton, III Allegheny Elec. Cooperative, Inc.
212 Locust Street P.O.
Box 1266 Harrisburg, Pennsylvania 17108-1266 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 Mr. Harold G. Stanley Vice President-Nuclear Operations Susquehanna Steam Electric Station Pennsylvania Power and Light Company Box 467 Berwick, Pennsylvania 18603 Mr. Herbert D. Woodeshick Special Office of the President Pennsylvania Power and Light Company Rural Route 1,
Box 1797 Berwick, Pennsylvania 18603 George T. Jones Vice President-Nuclear Engineering Pennsylvania Power and Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 Chairman Board of Supervisors 738 East Third Street
- Berwick, PA 18603
RE VEST FOR ADDITIONAL INFORMATION SUS UEKANNA STEAM ELECTRIC STATION SSES UNITS 1
AND 2 OBSERVATIONS ON SSES FIRE PROTECTION PROGRAMS AND SAFE SHUTDOWN ANALYSIS 1.
In Section 5.2 of the Control Room Analysis (CRA),
PP&L stated:
"Each component and associated cable identified in section
- 5. 1 was reviewed to determine whether proper isolation of the cable exists.
If isolation exists, component operability is assured outside the Control
- Room, and thus no further review was performed."
From this statement, it appears that if a component required to achieve alternative shutdown from outside the Control Room was provided with electrical isolation capability (i.e.,
an isolation/transfer switch),
PP&L assumed that no further review was necessary since fire damage would not occur prior to transfer.
Such an assumption appears to be contrary to NRC staff positions contained in Generic Letter 86-10 (Response to guestion 5.3. 10), Information Notice (IN) 85-09 and IN 92-18.
2.
Section 7.3 of the
- CRA, a number of modifications were discussed which were necessary to resolve deficiencies in the alternative SD capability.
These included: installation of a new alternative shutdown control panel for Control Structure HVAC, installation of new temperature switches to support EDG and ESW HVAC requirements, and isolation of EDG control circuits from fire damage.
These modifications were not discussed in Revision 4 of the FPRR.
3.
In Section 4.4.3 of the CRA PP&L stated that equipment damage due to hot shorts was not postulated based on the low probability of this condition affecting SSD.
This appears to be contradictory to NRC concerns identified in IN 92-18.
4.
PP&L in its submittal dated May 22, 1995, stated that no repai r activities are required to achieve hot shutdown conditions.
Notwithstanding this statement, the licensee's two procedures ON-100-009, and ON-200-009, "Control Room Evacuation,"
each Revision 3, for Units 1
and 2
respectively, in Step 4.3.4, instruct the plant operators to:
"NOTIFY I&C to install: (a) Temporary (reactor) level indication....,
and (b) Temporary reactor coolant temperature indication..."
As noted in IN 84-09, the staff considers reactor level indication as part of the minimum required instrumentation for alternative SSD for a BWR.
Since none of the approved or pending deviation requests appear to be related to a request by PP&L to seek approval for a Hot Shutdown repair to install temporary reactor level instrumentation, PP&L should explain why step "a", which is to be performed immediately after control has been established at the Remote Shutdown
- Panels, (i.e., in the early stages of Hot Shutdown) does not constitute a repair necessary to achieve and maintain hot shutdown.
Enclosure
5.
Section 6 of the Appendix R Analysis for a Control Room Fire identifies 17 calculations performed by PPIIL in support of its SSD Analysis.
These calculations are not referenced in the FPRR.
PPLL should have these calculations available for review.