ML18086B122
| ML18086B122 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 11/06/1981 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | Schneider F Public Service Enterprise Group |
| Shared Package | |
| ML18086B123 | List: |
| References | |
| TASK-2.E.4.2, TASK-TM NUDOCS 8112090492 | |
| Download: ML18086B122 (7) | |
Text
{{#Wiki_filter:---- Docket No. 50-272 Mr. F. W. Schneider, Vice President Production Public Service Electric and Gas Company 80 Park Plaza 15A Newark, Ne\\v Jersey 07101
Dear Mr. Schneider:
DISTRIBUTION Docket NRG PDR L PDR TERA NSIC ORB#l Rdg DEisenhut OELD IE-3 ACRS-10 SVarga EReeves GMeye'r CParrish Gray File o, y(-{tL tV/ In our letter of November 28, 1978, we identified the generic concerns of purging and venting of containments to all operating reactoi" licensees and requested your response to.these concerns. Our review of your response was interrupted by the TM! accident and its demands on staff resources. Conse-quently, as you know, an Interim Position on containment purging and venting was transmitted to you on October 30, 1979. You were requested to implement short-term corrective actions to remain in effect pending completion of our longer-term review of your response to our November 28, 1978 letter. Over the past several months we and our contractors have been reviewing.the responses to our November 1978 letter to close out our long-term review of this r,'lther complex issue. The components of this review are as folloi:1s:
- 1. Conformance to Standard f.!.eview Plan Section 6.2.4 Revision 1 and Branch Technical Position CSB 6-4 Revision 1.
These documents were provided as enclosures to our November 1978 letter.
- 2.
Valve Operability Although tile Interim Position allowed blocking of the valves at partial-open positions, this is indeed an interim position. Ear-lier we requested a program demonstrating operability of the valves in accordance with our "Guidelines for Demonstrative Operabili~y of Purge and Vent Valves. 11 These Gui de lines were sent to you in our letter of September ?..7, 1979. There is an acceptable alternative ~1hich you may wish to consider* in lieu of completing the valve qualifica-tion program for the large butterfly-type valves. This \\'/Ould be th~ installation. of a fully-qualified mini-purge system with valves 3-inches or smaller to bypass the larger valves. Such a system change m*i ght prove more timely and more cost-effective. Tile system would meet BTP CSB 6-4 item B.l.c. 8112090492 811106 PDR ADOCK 05000272 P PDR
r Mr. F. W. Schneider-3. Safety Actuation Signal Override This involves the review of safety actuation signal circuits to en-sure that overriding of one safety actuation signal does not also cause the bypass of any other safety actuation signal.
- 4. Containment Leakage Due to Seal Deterioration Position B.4 of the BTP CSB 6-4 requires that provisions be made to test the availability of the isolation function and the leakage rate of the isolation valves in the vent and purge lines, individually, during reactor operations.
But CSB 6-l/* does not explain when or how these tests are to be performed. is an amplification of Position B~4 concerning these tests. The status of our long-term review of the above items for the Salem Unit 1 facility is as follows:
- l. Conformance to Standard Review Plan Section 6.2.4 Revision 1 and Branch Technical Position CSB 6-4 Revision l.
This item is still under review. is a Safety Evaluation on this subject which describes the open items in this area. To resolve these issues you are requested to take the following actions: { 1) Debris Screens - By letter dated November 8, 1979, you provided a description of the debris screens installed in Salem Unit 2. ihis information was reviewed and approved in Supplement il to the Salem Unit 2 SER. Please provide information that identical screens are installed in Salem Unit 1. (2) Yearly Limit on Use of Pressure-Vacuum Relief System - You are requested to provide a commitment to a limit on the use of the pressure-vacuum relief system during modes l, 2, 3 and 4. This 1 imit shou1 d be expres$ed in terms of "hours per yearu and should reflect the objective of limiting the use of this system to the minimum required for safety-related reasons. The basis for the limit you select shall also be provided for our review. (3) Locked Closed 36-inch Purge Valves - You are requested to provide a proposed change to the Salem Unit 1 Technical Specifications which would require that the 36-inch purge isolation valves be maintained in the locked closed position during plant operating modes 1, 2, 3 and 4.
r Mr. F. w. Schneider (4) Leakage Integrity Tests - This issue is discussed separately below.
- 2. Valve Operability This item is still under review.
On June 18, 1981 we transmitted questions concerning your submittal on valve operability for Sal em Unit 2. By letter dated July 31, 1981 you provided your response to our June 18, 1981 request. This information for Salem Unit 2 is currently under review. You are requested to confirm that your response of July 31, 1981 is also applicable to Salem Unit 1.
- 3. Safety Actuation Signal Override We have completed our review. is our Safety Evaluation Report (SER} for this item. The SER identifies the following three exceptions:
(1) Inadequate physical protection is provided for the containment ventilation isolation reset push button switches 1 ocated in th1~ control room. DISCUSSION: This it.em was dicussed in a telephone conversation with Mr. J. Gagliardi of your staff on July 7, 1981. A plan to provide covers for the reset switches was agreed upon at that time. You are requested to provide a written description of the protective covers and confirmation that these covers have been installed. {2) The bypassing of a Safety Injection (SI) signal at the containment ventilation isolation (CVI) retentive memory is not annunciated. DISCUSSION: Your March 28, 1980 letter for Salem Unit 2 on this subject stated that the Salem design would be revised to include the alarm described above. Mr. J. Gagliardi, in our conversation on July 7, 1981, stated that the subject al arms have been installed in both Units l and 2. We consider this exception closed with no . further action required. (3) The radiation monitors *that initiate containment ventilation isolation are not safety-grade.
Mr. F. W. Schneider -~4-DISCUSSION: This requirement has been included in Revision 1 to Regulatory Guide 1. Ml. When this document is approved by the Commission we will request a commitment from you to upgrade these radiation monitors to safety-grade. Until that time no further action is required on this item.
- 4.
Containment Leakage Due to Seal Deterioration We request that you propose a Technical Specification change incorporating the test requirements together with the details of your proposed test program within 45 days of receipt of this letter. In closing, you may have noted the similarity of this long-term generic issue with Item I!.E.4.2 of MUREG-0737, TM! Action Plan. Except for Posi-tions 5, 6 & 7 of Item II.E.4.2, the review of the remaining outstanding positions of Item II.E.4.2 will be completed by this purge and vent review. Our schedule of the purge and vent review agrees with the schedule for Item II.F..4.2. Thus, your assistance in completing the outstanding purge and vent items, noted above, is necessary to complete Item II.E.4.2. Although the Technical Specifi-cations necessary to finalize the purge and vent part of Item II.E.4.2 are not completely finalized, a recently developed sample Technical Specification iS provided for your consideration as Enclosure 4. We request that you review existing Technical Specifications (TS) against the sample provided herein. For any areas in which your existing TS needs expansion, you are requested to pro-vide a TS change request within 60 days of receipt of this letter. This TS change should reflect the requirement that the containment purge and exhaust isolation valves are to be locked closed at all times in modes 1, 2, 3 and 4; and the vacuum-pressure relief isolation valves may be opened intermittently, under administrative control, for safety-related reasons. Pl ease contact your NRC Project Manager should you have any questions.
Enclosures:
As stated cc \\*1/enclosures: See next page Sincerely, Steven Ac Varga, Chief Operating Reactors Branch #1 Oivision of Licensing _ _ _ ~FF~~E~ ~~*~~~.~ .. ~~._... _.~.~~~... suRNAME* **** 9.....Y~x.;.Q.$...... IR...... Ei!.?~........ ~ DATE **** JQ/.~/..8.1........ J.QjJ..JJ.8.J.......J NRG FORM 318 (10-80) NRCM 0240 USGPO: 1981-335-960
Mr. F. W. Schneider Public Service Electric and Gas Company cc: Mark J. Wetterhahn, Esquire Conner, Moore and Corber Suite 1050
- 1747 Pennsylvania AveMue, NW Washington, D. C.
20006
- Richard Fryling, Jr., Esquire*
Assistant General Solicitor Public Service Electric and Gas Company 80 Park Pl ace Newark, New Jersey 07101 Gene Fisher, Bureau of Chief Sureau of Radiation Protection 380 Scotch Road* Trenton, New Jersey 0.8628 Mr. R. L. ~1itt1, Ge.neral -Manager Licensing and Environment Public Se~vice Electric and Gas.* Company 80 Park Plaza 17C New a r.k, New Jersey* 07101 Mr.* Henry J. Midura, Manager Salem Nuclear Generating Station Public Service Electric and Gas Company P. O. Box 168 Hancocks Bridge, New Jersey 08038 Sal em Free Library 112 West Broadway Salem, New Jersey 08079 Leif J. Norrholm, Resident Inspector Salem Nuclear Generating Station
- u. s. Nuclear Regulatory Commission Drawer I Hancocks Bridge, New Jersey 08038 John M. Zupko, Jr., Manager Nuclear Operations Support Public Service Electric and Gas Company 80 Park Plaza - 15A Newark, New Jersey
- 07101 Mr. R. A. Uderitz General Man~ger, Nuclear Production Public Service Electric and Gas Company 80 Park Plaza lSA Newark, New Jersey 07101 Mr. J. T. Boettger General Manager, Quality Assurance I&E Public Service Electric and
. Gas Company 80 Park Plaza Newark, New Jersey 07101 Mr. Edwin A. Li den, Manager Nuclear Licensing Licensing and Environmental Dept. Public Service Electric and Gas Company 80 Park Plaza 160 Newark, New Jersey 07101
PURGE/VENT VALVE LEAKAGE TESTS The long tenn resolution*of Generic Issue B-24, "Containment Purging During Normal Plant Operation," includes, in part, the implementation of Item B.4 of Branch Technical Position (BTP) CSB 6-4. Item B.4 specifies that provisions should be made for leakage rate testing of the (purge/vent
- system) isolation valves, individually, during reactor operation. Although Item B.4 does not address the testing frequency, Appendix J to 10 CFR Part 50 specifies a maximum test.interval of 2 years.
As a result of the numerous reports on unsatisfactory perfonnance of the. resilient seats for the isolation valves in containment purge and vent lines (addressed in OIE Circular 77-11, dated September 6, 1977), Generic Issue B-20, "Containment Leakage Due to Seal Deterioration," was established to evaluate the matter and establish an appropriate testing frequency for the isolation valves. Excessive leakage past the resilient seats of isolation. valves in purge/vent lines is typically caused by severe environmental con-ditions and/or wear due to frequent use *.
- Consequently, the leakage test frequency for these valVes should be keyed to the occurrence of severe environ-mental conditions and the use of the valves, rather than the current require-ments of 10 CFR 50, Appendix J~
It is recommended that the following provision be added to the. Technical Specifications for the leak testing of purge/vent line isolation valves: "Leakage integrity tests shall be performed on the containment isolation valves with resilient material seals in (a) active purge/vent systems (i.e., those which may be operated during plant operating Modes 1 through 4) at least once every three months and (b) passive purge systems (i.e., those which must be administratively controlled closed during reactor operating Modes 1 through 4 )* at 1 east once every six.months. 11 By way of clarification,* the above proposed surveillance specification is predicated on our expectation that a plant would have a need to go to cold shutdown several times a year. To cover the possibility that this may not occur, a maximum test interval of 6 months. is specified. However, it is not our intent to require a plant to shutdown just to conduct the valve leakage integrity tests. If licensees anticipate long* duration power oper-ations with infrequent shutdown, then installation of a leak test connection that is accessible from outside containment may be appropriate. This will pennit simultaneous testing of the* redundant valves *. It will not be possible to satisfy explicitly the guidance of Item B.4 of BTP CSB 6-4 (which states that valves should be tested individually), but at least some testing of the valves during reactor operation will be possible.
- It is intended that the above proposed surveillance specification be applied to the active purge/vent 1 ines, as well as passive purge lines: i.e., the purge lines that are administratively controlled closed during reactor oper-ating modes 1-4. The reason for including the passive purge lines is that B-20 is concerned wtih the potential adverse effect of seasonal weather con-ditions on-the integrity of the isolation valves. Consequently, passive purge 1 ines must al so be included i_n the surveillance program.
The purpose of the leakage integrity tests of the isolation valves in the containment purge and vent. lines is to identify excessive degradation -of _the resilient seats for these valves. Therefore, they need not be conducted with the precision required for the Type C isolation valve tests in 10 CFR Part 50, Appendix J. These tests would be perfonned in addition to the quantitative Type C tests required by Appendix J and would not relieve the 1 i censee of the res pons i bi 1 i ty to confonn to the requirements of Appendix J. In view of the wide variety of valve* types and seating materials, the - acceptance criteria for such tests should be developed on a plant-specific* basis. 'I}}