ML18089A458
| ML18089A458 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 11/17/1983 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | Uderitz R Public Service Enterprise Group |
| References | |
| GL-82-28, NUDOCS 8312080270 | |
| Download: ML18089A458 (8) | |
Text
- .
Docket Nos. 50-272 and 50-311
- Mr. Richard A. Uderitz Vice President - Nuclear Public Service Electric and Gas Company P. 0. Box 236 Hancocks Bridge, New Jersey 08038
Dear Mr. Uderitz:
We have completed our review of your April 22, 1983 response to our December 10, 1983 Generic Letter 82-28 11 Inadequate Core Cooling Instrumen-tation (ICCI) System 11 and concluded that the described modifications to the generic Westinghouse Differential Pressure system are acceptable. However, our implementation review, including an August 2, 1983 status report by
- Public Service Electric and Gas Company and our September 12, 1983 visit to the plant for audit of the ICCI, is incomplete.
We require that you provide the implementation letter report described in Enclosure 2 in order that the staff can complete their review for implementation approval of the installed reactor vessel level instrumentation system.
The enclosed SER (Enclosure 3) presents the results of our review, identifies deficiencies in the existing core exit thermocouple and saturation margin monitor systems, and requests additional information relative to conformance of these components of the ICCI system to NUREG-0737 design requirements.
We request that you initiate the necessary actions to implement the ICCI system, and provide a schedule for additional submittals, including responses to Enclosures 1 and 2, within 30 days from receipt of this letter.
Enclosures:
- 1.
Request for Additional Information
- 2.
Milestones for Implementation of Inadequate Core Cooling Instrumentation
- 3.
Evaluation of PSE&G 1s
Response
cc w/enclosures:
See next page Sincerely, Steven A. Varga, Chief Operating Reactors Branch No. 1 Division of Licensing DISTRIBUTION Docket File NRC PDR L PDR NSIC ORB#l Rdg EJordan JTaylor ACRS-10 CParrish DFischer OELD ORBH-riB£ DF~~:dm 11116/83 8312080270 831117 PDR ADOCK 05000272 P
Publi~ Service Electri~ and Gas Company cc:
Mark J. Wettei::;hahn, Esquire Conner and Wetterhahn Suite 1050 1747 Pennsylvania Avenue, NW Washington, D. C.
20006 Richard Fryling, Jr., Esquire Assistant General Solicitor Public Servic~ Electric and Gas Company Mail Code TSE - P.O. Box 570 Newark, New Jersey 07101 Gene Fisher, ~~reau of Chief Bureau of Radiation Protection 380 Scotch Road Trenton, New Jersey 08628 Mr. R. l. Mittl, General Manager Nuclear Assurance and Regulation Public Servfce Electric and Gas Company Mail Code Tl6D -
~.o. ~ox 570 Newark, New Jersey 07101 Mr. John M. Zupko, Jr.
General Ma1ager - Salem Operations Public Service Electric and Gas Company P. 0. Box E Hancock Bridge, New Jersey 08038 Leif J. Norrholm, Resident Inspector Salem Nucl~ar Generating Station U.S. Nuclear Regulatory Commission Drawer I Hancocks Bridge, New Jersey 08038 Mr. Edwin A. liden, Manager -
Nuclear Licensing Public Service Electric and Gas Company Post Office Box 236 Hancocks Bridge, New Jersey 08038 Regional Administrator - Region I U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 194106 Mr. Charles P. Johnson Assistant to Vice President - Nuclear Public Service Electric and Gas Company P.O. Box 570 80 Park Plaza - 15A Newark, New Jersey 07101
ENCLOSURE l REQUEST FOR ADDITIONAL INFORMATION PUBLIC SERVICE ELECTRIC AND GAS COMPANY PROPOSED INADEQUATE CORE COOLING INFORMATION FOR SALEM GENERATION STATION UNITS l AND 2
- 1.
Provide the calibration procedures used for the RVLIS as discussed during the NRC plant visit on September 12, 1983.
- 2.
At the time of the plant visit, the use of the RVLIS was not incorporated either in the emergency procedures or in the plant training simulator.
Provide a schedule for accomplishing this.
- 3.
Provide revised Technical Specifications dealing with ICCI.
- 4. Temperature measurement and compensation is not provided for all independently run vertical sections of impulse lines. Provide an estimate of additional error this may cause in level indication with degraded environment.
- 5. According to the referenced submittals, the CET system is not completely environmentally qualified and does not meet all the requirements of NUREG-0737, II.F.2, Attachment l. Clarify ~he PSE&G position with respect to meeting these design requirements and provide a schedule for upgrade.
- 6.
Clarify the PSE&G position with respect to II.F.2, Attachment l requirements for Back-up Displays and provide a schedule for upgrade.
Areas of concern include:
(a) environmental and seismic qualification per Regulatory Guide l.89; (b) ability to read 16 thermocouples in less than six minutes; (c}
four qualified thermocouples per quadrant; (d) measurement and display range of 200°F to 2300°F; (e) energized from lE power source and electrically independent of primary display; (f) signals electrically isolated from primary display; (g) display accessible to**the operator and human factored; and
{_h) operator use integrated into emergency procedures.
- 7.
Clarify the PSE&G position with* respect to requirements of II.F.2, for primary displays.
Provided a schedule for upgrade.
- 8.
Provide a detailed description of the final integrated display system for ICC information indicated by the CETs, SMM, and RVLIS.
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EN~LOSURE 2 MILESTONES FOR IMPLEMENTATION OF INADE6UATE CORE COOLING INSTRUMENTATION
- 1.
Submit final design desc;iption (by licensee) (complete the docu-mentation requirementS of NUREG-0737, Item II.F.2, including all plant~specific information items identified in applicable NRC evaluation reports for generic approved systems).
- 2.
Approval of emergency operating procedure (EOP} technical guidelines (by NRC}.
Note: This EOP technical guideline which incorporates the selected system must be based on the intended uses of that system as described in approved generic EOP technical guidelines relevant to the selected system.
- 3.
Inventory Tracking Systems (ITS) installation complete (by licensee).
- 4.
ITS functional testing and calibration complete (by licensee).
- 5.
Prepare revisions to plant operating procedures and emergency procedures based on approved EOP guidelines (by licensee).
- 6.
Implementation letter* report to NRC (by licensee).
- 7.
Perform procedure walk-through to complete task analysis portion of ICC system design (by licensee).
- 8.
Turn on system for operator training and familiarization.
- 9.
Approval of plant-specific installation (by NRC).
JO.
Implement modified operating procedures and emergency procedures (f>y licensee).
- System Fully Operational -
- Implementation Letter Report Content (1)
Notification that the system installation, functional testing, and calibration is complete and te~t results are available for in-spection.
(2) Sumnary of 'licensee conclusions based on test results, e.g.:
(a} the system perfonns in accordance with design expectations and within design error tolerances; or (b) description of deviations from design performance specifications and basis for concluding that the deviations are acceptable.
(3) Description of any deviations of the as-built system from previous
- design descri"ptions with any appropriate explanati"on.
(4). Request for modification of Technical Specifications to include all ICC i.nstrumentation for accident 100nitoring.
(5) Request for NRC approval of the plant-specific installation.
(6) Confinn that the EOPs used for operator training will conform to the technical content of NRC approved EOP guidelines (generic or plant specific).
ENCLOSURE 3 EVALUATION OF PUBLIC SERVICE ELECTRIC AND GAS COMPANY RESPONSE TO U.S. NRC GENERIC LETTER 82-28 "INADEQUATE CORE COOLING INSTRUMENTATION SYSTEM" DECEMBER 10, 1982 In response to the U.S. NRC Generic Letter No. 82-28 "Inadequate Core Cooling Instrumentation (ICCI) System" dated December l 0, 1982, Public Service Electric and Gas Company (PSE&G) has proposed a system for detecting and monitoring ICC conditions including subcooling margin monitor (SMM), core exit thermocouples (CET), and reactor vessel level instrumentation system (RVLIS).
The staff in conjunction with our contractor, Oak Ridge National Laboratory (ORNL), has reviewed the PSE&G submittals dated October 27, 1981 and April 22, 1983 in response to the subject letter and a status report dated August 2, 1983.
An audit of the Salem ICCI system was performed on September 12, 1983 in order to expedite our review.
Reactor Coolant Inventory Tracking System (ITS)
Th~ RVLIS proposal is a ~ifferential pressure (dp) measurement concept in accordance with the generic Westinghouse (W) dp system proposal with no claimed exceptions.
Installation of RVLIS-systems in both units of the plant is complete. Scaling, calibration anp testing is complete on Unit l and nearing completion on Unit 2. Three field design changes are being made.
The first two changes involve addition of capacitors to the microprocessors to correct difficulties identified during testing and the removal of unneeded bypass valves from the dp transmitters. The third change will upgrade the seismic design and incorporate some human factors modifications.
Based on our review we have found that the PSE&G proposal of its installed generic !i dp system with modifications is acceptable. However, we will require that PSE&G provide the implementation letter report described in in order that we can complete our review for approval of the RVLIS implementation.
The milestones relating to implementation of the system, as provided in Enclosure 2, should be incorporated into the Salem schedule.
During the audit, it was agreed that the RVLIS should be made operational for operator familiarization and training after emergency operating procedures have been modified to incorporate RVLIS and after the licensee has completed a walk through and task analysis of these modified procedures.
Temporary "dummy" modifications to procedures, for the training simulator will incorporate RVLIS to expedite the operator training.
\\..
I,
- Core Exit Thermocouples There are. 65 in-core thermocouples 1:ba,t _fe~g_ into_ the station computer which is energized from an uninterruptible power supply. A primary display CRT is located on the control console.
The backup display is supplied from redundant station power sources.
The backup display and hardware are not Class lE.
The in-core thermocouples, their* electrical connectors and reference junction boxes are not environmentally qualified in accordance with NUREG-0737 Appendix B.
No schedule was provided for the upgrading of the thermocouple system.
The staff concerns regarding the backup display of the CETs are provided in Enclosure 1. Public Service Electric and Gas Company has provided justification for continued use of in-core thermocouples as follows:
"Current procedures instruct the operator-to monitor the in-core thermo-couples as a guide to determining the existence of adequate core cooling.
Westinghouse information and operating history of these devices indicate that they would function.
If these devices were to fail, backup parameters, such as, RCS pressure and temperature, steam generator level, and auxiliary feedwater flow are available to enable determination of adequate core cooling. These backup devices are qualified and are described in the procedure which also alerts the operator to potential errors in the in-core temperature readings."
Based on SECY-82-407 "Implementation of TMI Action Pl an II. F.2 (NUREG-0737)," which was approved by the Commissioners on November 4, 1982, upgrading the CET system is required.
Public Service Electric and Gas Company should provide additional information, including the schedule and details of th~ upgrading of the existing CET system, to resolve the staff concerns described in Enclosure 1 relative to conformance of the CET system to the NUREG-0737 design requirements.
Subcooling Margin Monitor Public Service Electric and Gas Company has installed a subcooling meter which consists of 65 temperature inputs from the CETs plus two pressure inputs from a reactor coolant loop.
The margin of subcooling is calculated by the plant process computer and is continuously displayed on a trend recorder near the computer output printers. The following information can be called up from the plant process computer and displayed on a CRT on the main console:
highest thermocouple temperature, system pres$ure, saturation temperature, margin to saturation (in PSI and °F) and t~e location of the hottest thermocouple.
The selection logic used for SMM is the highest in-core thermocouple reading and the average of two reactor coolant pressures.
The operator is provided with the capability_
to reject the selected thermocouple and the next highest reading thermo- *- *-.,...._
couple will then be automatically selected for the calculation. The SMM has been upgraded with qualified pressure transmitters and recorders have been relocated.
However, the temperature input to SMM is from the non-qualified CET system.
. \\
~... Conclusion Based on our review of the PSE&G response to Generic Letter No. 82-28, we have concluded that the proposed generic W approach to the RVLIS with modifications is acceptable.
The PSE&G submfttals are responsive to the December 10, 1982 Generic Letter No. 82-28 and address most of the information requested by the staff. There are some remaining concerns related to the specific implementation of the system at the plants.
We are requesting additional information in Enclosure l to address our concerns relative to conformance of components of the ICC! system (especially, the CET system) to NUREG-0737 !~esign requirements.