ML18092A252

Forwards Responses to 840504 Ltr Re Inel Rept on Util Conformance to Reg Guide 1.97 Requirements for Emergency Response Capability & Suppl 1 to NUREG-0737.Changes to 830921 Implementation Plan Listed

ML18092A252
Person / Time
Site:	Salem
Issue date:	08/09/1984
From:	Liden E Public Service Enterprise Group
To:	Varga S Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737 NUDOCS 8408150223
Download: ML18092A252 (9)

Text

e OPS~G Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038 Nuclear Department August 9, 1984

u. s. Nuclear Regulatory Commission Off ice of Nuclear Reactor Regulation Division of Licensing Washington, D. c. 20555 Attention: Mr. Steven A. Varga, Chief Operating Reactors Branch, No. 1

Dear Mr. Varga:

CONFORMANCE TO REGULATORY GUIDE 1.97 REQUIREMENTS FOR EMERGENCY RESPONSE CAPABILITY SUPPLEMENT 1 TO NUREG-0737 SALEM GENERATING STATION UNITS NO. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 Your letter dated May 4, 1984, transmitted an interim report by Idaho National Engineering Laboratory (INEL) on PSE&G's implementation of Regulatory Guide 1.97, Revision 2. INEL identified 18 items deviating from the guidance of Regulatory Guide 1.97. The attached response addresses each of those items and either provides additional justification for the deviation or contains a commitment to up~rade the instrumentation.

PSE&G wishes also to make the following changes to the implementation plan transmitted on September _21, 1983:

a. The range for variable No. 35 "Steam Generator Level" should be changed from 0-500 inches to 0-575 inches. (see Item 11 in attachment) r94oa-1-s-0223 *-a-40-809 PDR ADOCK 05000272 F PDR The Energy People

Mr. Steven A. Varga 8/9/84

b. It was indicated that the transmitters for variable Nos. 48 and 49, "Component Cooling Water Temperature to ESF System" and "Component Cooling Water Flow to ESF System" respectively, are located in a benign environment. These instruments are actually located in a harsh environment and the instrumentation for the component cooling water temperature will be qualified to meet Regulatory Guide 1.97. The component cooling water flow is fixed by throttle valves which are locked open, so a flow indication is not necessary. We feel that qualification is not required for the following reasons:

i. The flow is not addressed in the Emergency Operating Procedures.

ii. The presence of flow can be verified by monitoring the component cooling water pump status (motor amperes). This instrumentation is available.

c. The location of tap to tap for variable No. 30 "Pressurizer Level" should be changed from 3 feet 4 inches and 47 feet 2 inches to 4 feet 10 inches and 48 feet 8 inches. The span of 43 feet 10 inches remains unchanged.

All commitments made in this response, with the exception of Item No. 16, will be completed by the sixth refueling outage for Unit No. 1 and the third refueling outage for Unit No. 2, which are presently scheduled for February 1986 and for September 1986, respectively. The schedule for Item No. 16 will follow that of the Safety Parameter Display System which has a completion date of December 1986. We request that you amend your Confirmatory Order of June 12, 1984 to reflect these changes.

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Mr. Steven A. Varga

• 8/9/84 Should you have any questions, please contact us.

Sincerely, E. A. Liden Manager - Nuclear Licensing and Regulation Attachments (all)

C Mr. Donald C. Fischer Licensing Project Manager Mr. James Linville Senior Resident Inspector

SALEM GENERATING STATION UNITS NO. 1 AND 2 RESPONSE TO NRC LETTER DATED MAY 4~ 1984

REFERENCE:

~EG'S RESPONSES TO REGULATORY GUIDE 1.97, REV. 2, DATED APRIL 2, 1981, APRIL 15, 1983, AND SEPTEMBER 21, 1983.

This response was prepared on an item by item basis as outlined in section 4.0 of the interim report dated May 4, 1984 which was prepared by Idaho National Engineering Laboratory (INEL} for the NRC.

1. NEUTRON FLUX PSE&G is committing to install qualified detectors for the Power, Source and Intermediate ranges. The installation of these detectors will be contingent on PSE&G's review of the vendor's qualification test reports.

2. RADIATION LEVEL IN CIRCULATING PRIMARY COOLANT We feel that the Post Accident Sampling System is adequate to determine the radioactivity level*in the circulating primary coolant on a long term basis.

3. RADIATION EXPOSURE RATE

a. PSE&G will comply with the range for this instrumentation. The range will.be l0-1 to 107R/hr.

b. PSE&G has committed to providing this instrumentation for Unit No. 1 in a letter to the NRC dated May 16, 1984.

4. EFFLUENT RADIOACTIVITY - NOBLE GASES FROM ELECTRICAL AND MECHANICAL PENETRATION AREAS AND FUEL HANDLING BUILDING

.a. The Mechanical Penetration Area and Fuel Handling Building exhaust through the plant vent. The plant vent monitors meet Regulatory Guide 1.97 requirements.

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b. There is no significant source of release in the electrical penetration area so we feel that an effluent monitor is not necessary. The worse case is -a Post Accident Sampling System sample tubing rupture. If this condition occurs, the system can be isiblated remotely from the Post Accident Sampling System panel which is located in a non-harsh environment.

5. RESIDUAL HEAT REMOVAL HEAT EXCHANGER OUTLET TEMPERATURE The Residual Heat Removal Exchanger Outlet temperature indication is not used by the operator during an accident so we feel that the instrumentation does not have to be qualified. An alternate means of determining this temperature is by the use of the Reactor Coolant System Cold Leg Resistance Temperature Detectors. These detectors are qualified.

6. ACCUMULATOR TANK LEVEL The top and bottom of the tanks are hemispheres which are non-linear. The benefits from an operation standpoint, of monitoring 10% to 90% of the volume of the tank cannot justify the cost of installing the necessary instrumentation. It should be noted that the original intent for monitoring the accumulator tank level is to ensure that there is an adequate volume of borated water for a loss of coolant condition. The range that will be monitored satisfies this intent and we feel that it is adequate.

7. REFUELING WATER STORAGE TANK LEVEL The top of the tank discharge line to the suction of the Residual Heat Removal, Safety Injection and Charging Pumps is 1.83 feet from the bottom of the tank -

so there is only a difference of 0.67 feet between that level and the lower limit of 2.5 feet. This is acceptable because 0.67 feet .is only 1.54% of the total possible height of the tank that can be monitored. The interim report indicates that the upper limit of the span is effectively the top of the tank, so the conclusion is that the range of 2.5 feet to 45.24 feet meets Regulatory Guide 1.97 requirements.

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8. PRESSURIZER LEVEL The range presently being monitored is 4 feet 10 inches to 48 feet 8 inches. This range is equivalent to the tap to ta:G> span for the transmitter which is the linear portion c:4. the pressurizer. We feel that the range being monitored is adequate for the following reasons:

a. The range being monitored is 84.4% of the total height of the pressurizer.

b. It provides the required information for the operator to take the necessary corrective action during a transient.

c. The minimum water level indicated is 11 feet 3 1/8 inches which is above the electric heaters.

d. The range being monitored. in terms of percentage of total pressurizer height is 9.3%

to 93.7%.

9. PRESSURIZER HEATER STATUS The Pressurizer Heater Cables are not qualified because of the following:

a. The heaters are backed* by diesel power.

b. They are not safety related, not required for a loss.of coolant accident, and not required for Appendix R, so the cables are not required to be qualified. *

10. QUENCH TANK LEVEL The range of 7 in. to 8 ft., 11 in. is equivalent to a volume of 13,811.36 gallons and the total volµme of the tank is 15,465 gallons. This indicates that approximately 90% of the volume is being monitored; having a range of 5% to 95% of volume and this is considered to be adequate for post accident monitoring. It should also be noted that 25% of volume of the tanks is occupied by inert nitrogen gas which is used to prevent the possibility of oxygen and hydrogen gas from combining in an explosive manner. We feel that the range being monitored is adequate.

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11. STEAM GENERATOR LEVEL

a. The Emergency Operating Procedures provide adequate guidance for having only one channel of wide range level 1 per steam generator. This was based on westi~ghouse Emergency Response Guidelines.

Because of the aforementioned, we feel that redundant instrumentation is not required.

b. The actual range being monitored is 106 ft., 8 in.,

to 154 ft., 7 in., a total of 575 inches. This range corresponds to 12 inches above the tube sheet to the seperators, and we feel that this range is adequate.

12. CONTAINMENT SPRAY FLOW The containment spray additive flow instrumentation is used as indirect indication of containment spray flow.

The instrumentation meets the requirements of Regulatory Guide 1.97. After the additive tank is depleted, containment spray flow can be verified by monitoring the containment spray pump status (motor amperes) and the pump motorized discharge valve position. These indications are available in the control room. We feel that these alternatives are adequate for determining containment spray flow.

13. HEAT REMOVAL BY THE CONTAINMENT FAN HEAT REMOVAL SYSTEM There is instrumentation which provides indication of fan operation (start/stop, high speed/low speed). This instrumentation meets the requirements of Regulatory Guide 1.97 based on category of the parameter. It should also be noted that the fan c.ooler outlet flow and fan operation indication will be displayed on the Safety Parameter Display System.

14. CONTAINMENT SUMP WATER TEMPERATURE Containment sump temperature instrumentation is not required for Residual Heat Removal operation or assurance of net positive suction head (NPSH) availability since NPSH calculations conservatively assume saturated water is present. However, the Residual Heat Removal Heat Exchanger inlet temperature instrumentation is an alternate.

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15. RADIOACTIVE GAS HOLDUP TANK PRESSURE The range being monitored for this parameter is 0 - 150 PSIG. - This range is adequate for the following reasons*: f_

1. The design pressure for the tanks and compressors is 150 PSIG.

2. The operating pressure for the tanks and

• compressors is 0 - 110 PSIG.

3. The control arrangement for the tanks inlet header allows the operator to place one tank in -service and select another as a standby. Flow is automatically switched to the standby tank when the tank in service is filled to 110 PSIG. The inlet valve to the tanks in service closes when the pressure reaches 110 PSIG.

4. There is a high pressure alarm and a pressure relie~ valve for each tank, the alarm set point is 135 PSIG, and the relief valve is set at 150 PSIG.

5. The waste disposal system will not operate during or immediately after a loss of coolant accident.

During long term recirculation some periodic use may be required.

16. EMERGENCY VENTILATION DAMPER POSITIONS Damper positions for the Auxiliary and Fuel Handling Buildings will be displayed on the SPDS and the CRTs will be located in the Control Room, Technical Support Center and the Emergency Offsite Facility.

17. COMMON PLANT VENT FLOW RATE*

This instrumentation is provided and the range is 0-150.000 CFM. During normal operation, the anticipated flow is approximately 80,000 CFM therefore the range being monitored is more than 110% as required*

by Regulatory Guide L 97. _

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18. NOBLE GAS VENT FROM STEAM GENERATOR SAFETY RELIEF VALVES OR ATMOSPHERIC DUMP VALVES

a. The range of the main steam monitors is l0-1 to 103 micrq-~urrie/cc which meets the required range for thisfparameter.

b. The duration of the safety relief valves opening can be determined using the main steam flow recorder. This can be accomplished in the following manner:

1. The flow through each valve is 20% of the total main steam flow or approximately 700,000 lbs/hr.

2. When the main steam isolation valves close, the flow will be zero. When the first safety relief valve opens, the flow will increase to 700,000 lbs/hr, when the second valve opens, the flow will increase to 1,400,000 lbs/hr etc.

3. This activity will reverse as the valves close and *the duration of release and the flow can be determined from the trend recorder.

c. The same argument holds true for the atmospheric dump valves except that there is only one valve for each steam gene:i;ator and the flow through that valve is 10% of the main steam flow or 350,000 lbs/hr.

It should be noted that when the atmospheric dump valve and one safety relief valve open the flow will be approximately 1,050,000 lbs/hr. The

, atmospheric dump valves have open and close indication. We feel that the instrumentation used to monitor duration of release and the mass of steam per unit time is adequate and meet Regulatory Guide 1.97 requirements.

MHA:ljs 7/25/84 D8/10 6