ML18085A425

Clarifies Inability to Comply W/Tech Spec Requirements Per Amend 27.Margin of Safety Available from Charging Safety Injection Pumps Shown.Operation W/Tested Flow of 10 Gpm Below Tech Specs Does Not Compromise Safety Limits

ML18085A425
Person / Time
Site:	Salem
Issue date:	12/19/1980
From:	Uderitz R Public Service Enterprise Group
To:	Varga S Office of Nuclear Reactor Regulation
References
NUDOCS 8101050083
Download: ML18085A425 (5)

Text

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Public Service Electric and Gas Company 80 Park Place Newark, N.J. 07101 Phone 201/430-7000 Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Attention:

Mr. S. A. Varga, Chief Operating Reactors Branch 1 Division of Licensing Gentlemen~

COMMENTS ON AMENDMENT NO. 27 NO. 1 UNIT SALEM GENERATING STATION DOCKET NO. 50-272

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This letter will confirm and clarify our inability to document compliance with Technical Specification Surveillance Requirements 4.5.2.h.l.a and 4.5.2.h.2.a, transmitted to Public Service Electric and Gas Company in Amendment No. 27 to Facility Operating License No. DPR-70 on November 28, 1980.

Relief from the first requirement was granted by telephone by Mr. S. A. Varga on December 18, 1980 for the purpose of proceeding with plant startup.

The incorporation of additional ECCS Surveillance Requirements was requested by the NRC Staff and proposed changes were sub-mitted by Public Service Electric and Gas Company by letter on June 29, 1978.

The requirements received in Amendment No. 27 were more restrictive than anticipated and we are unable to document, by means of preoperational testing, that these specifications have been initially satisfied.

Relief is requested immediately for the requirement to demonstrate that baseline conditions conform to these requirements.

We will, of course, retest as specified after any future ECCS modifications which alter the subsystem flow charac-teristics.

These requirements were received after the unit's reactor vessel closure head was installed and we are currently proceeding towards initial criticality.

We are confident that existing test documentation assures adequate safety margins as discussed below.

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Dir. of Nuclear Reactor Regulation December 19, 1980 New Technical Specification requirements issued on Unit No. 1 for application after any modification to the ECCS piping requires demonstration that the sum of the flow from Charging Safety Injection Pump to the cold legs, less the highest leg, be ~346 gpm.

In reviewing original start-up data relative to the flow require-ment, it was found that the measured flow from each CSI pump was less than 346 gpm.

Subsequent retesting and refurbishing of #11 pump was evaluated by Westinghouse.

The attached curves generated by Westinghouse show the relationship of the Salem CSI pumps to the system performance required by the ECCS analysis.

The curve marked Figure 3 shows the margin of No. 12 pump.

The curve marked Figure A-1 shows the margin of No. 11 pump after refurbishing.

The data point at zero psig back-pressure for the ECCS performance curve is approximately 63.3 lb/sec., three-fourths of which is equal to the Technical Specification number of 346 gpm.

Similar mathematics for No. 12 pump from Figure 3 shows a Technical Specification equivalent of 359 gpm and for No. 11 pump from Figure A-1 an equi-valent of 362 gpm.

This demonstrates the margin of safety that is available from the Charging Safety Injection pumps.

New requirement 4.5.2.h.l.a for the Safety Injection Pumps requires that the sum of the injection line flow rates, excluding the highest flow to be ~463 gpm.

A review of the original startup data shows an actual value achieved after flow balancing to be 453 gpm.

Westinghouse has indicated that the 463 gpm is the number that was used in the ECCS analysis.

The critical consideration in this evaluation is the small break LOCA, where the sensitivity 'to this flow rate is greatest.

Westinghouse has indicated that the Salem flow reduction results in a peak clad temperature increase of 10°F.

Since the calculated small break LOCA peak clad temperature for Salem was 1465°F, an increase to 1475°F is not significant and is well within the acceptable range.

A further conservatism is the fact that Westinghouse used the higher Unit #2 plant rating (3411 MWe) in calculating the 1465°F.

It is therefore concluded that operation with a tested flow of 10 gpm below the Technical Specification limit does not compromise the safety limits of Salem No. 1.

w Dir. of Nuclear Reactor Regulation December 19, 1980 With regard to training of the Salem Station Fire Brigade, recent interpretation by Region I personnel has been that said training is not in accordance with the Station Fire Fighting Manual commit-ments.

In question is whether practice sessions properly train for "various types, magnitudes, complexity and difficulty as those which can occur in the plant", for each Fire Brigade member.

We understand that it is the position of Region I per-sonnel that these requirements can be satisfied only by the two day off-site fire fighting training provided to some of the Salem Fire Brigade personnel.

The composition and training of the existing Salem Fire Brigade is such that three brigade members on each operating shift have completed off-site training, with the remaining two having all other required training.

By January 31, 1981, the balance of the Fire Brigade could have their training supplemented with the off-site program, if required.

Without full knowledge for the basis of the current interpre-tation, we believe that the existing training satisfies the intent of the commitments in the Fire Fighting Manual, such that acceptable training is currently provided.

However, if it should be determined that current training is unsatisfactory, Fire Brigade training will be supplemented with off-site training by January 31, 1981.such that at least five Fire Brigade members per shift will have the additional training.

In addition, the existing Fire Brigade will be supplemented with one additional member without off-site training until such time that the inter-pretation of our Fire Fighting Manual is resolved.

On this basis we request relief from the interpretation of the existing technical specification.

Your prompt and favorable consideration of this request for relief will be appreciated.

CPJ:rp Sincerely, fi{j.~

R. A. Uderi t~

General Manager -

Nuclear Production

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