ML18093A245
| ML18093A245 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 07/15/1987 |
| From: | Miltenberger S Public Service Enterprise Group |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| GL-83-33, NLR-N87132, NUDOCS 8707230230 | |
| Download: ML18093A245 (9) | |
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Public Service Electric and Gas Company Steven E. Miltenberger Vice President -
Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609 339-4199 Nuclear Operations JUL 1 5 1987 NLR-N87132 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-272/83-37 SALEM GENERATING STATION UNIT NO. 1 DOCKET NO. 50-272 Public Service Electric and Gas Company (PSE&G) is in receipt of your letter dated June 15, 1987, which transmitted a Notice of Violation involving three conditions indicative of a failure to provide adequate fire protection features to achieve and maintain safe shutdown conditions as required by 10CFR50, Appendix R.
Pursuant to the provisions of 10CFR2.201, the PSE&G ~esponse to the subject Notice of Violation is attached.
You will note in our responses to the specific items of the Notice of Violation that we do not agree that these items should be classified as violations, nor do we agree with the stated severity level if the violations stand.
It is PSE&G's position that should the violations stand they should be classified as Severity Level IV as opposed to Severity Level III.
It is our belief that the alleged violations were assessed due to uncertainties regarding the implementation of 10CFR50, Appendix R requirements at Salem Unit 1.
Over the past several years, Appendix R implementation guidance has been extensively modified and, in some cases, previous guidance was determined to be no longer applicable.
PSE&G has identified and reported deficiencies, initiated efforts to correct these deficiencies, and applied for exemptions from the regulation where applicable in light of this guidance.
The noted violations appear to be based more upon alleged deficiencies in our interpretation of NRC Appendix R implementation guidance than upon the regulation itself.
Salem Unit 2 was reviewed and inspected for compliance with Appendix R requirements by the NRC in 1981.
When new Appendix R guidance was issued through NRC Generic Letter 83-33, PSE&G responded and identified areas not in compliance with this guidance.
After a 1984 NRC inspection of Salem Unit 1, PSE&G took additional steps to comply with identified deficiencies.
8707230230 B~8bb~72 PDR ADOCK 0 PDR G
JUL 1 ;i 1987 Document Control Desk 2
The configurations described in the Notice of Violation all involve items which, subsequent to the NRC reviews and inspections noted above, have become the subject of 10CFR50, Appendix R exemption requests.
These configurations are also similar to those which have been approved at other plants as exemptions to the rule or as engineering evaluations without NRC staff approval.
Since 1984, the NRC has changed the guidance with regard to the implementation of Appendix R by way of Generic Letters 85-01 and 86-10 and as presented in subsequent Regional workshops.
As a result, many of the modifications made at the Salem units in response to the 1984 inspection exceed the current inter-pretations of the rule.
PSE&G has undertaken an extensive effort to establish a,comprehensive Appendix R program for Salem which ensures present and future compliance with the most recent guidance and NRC staff interpretations regarding Appendix R.
Final resolution of the previously submitted exemption requests is an integral part of the formulation of this program.
NRC review of the submitted exemptions requests is still ongoing.
Based on the above discussion, PSE&G feels that classification of these items as violations is not warranted.
Please contact us with your questions regarding this violation response.
Your cooperation in this matter is appreciated.
Sincerely, Attachment C
Mr. D. C. Fischer USNRC Licensing Project Manager -
Salem Mr. T. J. Kenny USNRC Senior Resident Inspector -
Salem Mr. w. T. Russell, Administrator USNRC Reg ion I Mr. D. M. Scott, Chief Bureau of Nuclear Engineering Department of Environmental Protection 380 Scotch Road Trenton, NJ 08628
ATTACHMENT 10CFR2.201 INFORMATION PUBLIC SERVICE ELECTRIC AND GAS COMPANY SALEM GENERATING STATION RESPONSE TO NOTICE OF VIOLATION The NRC letter dated June 15, 1987, identified three plant conditions at the Salem Generating ~tation which were determined to be in violation of the requirements of 10CFR50, Appendix R.
Our response*to the specific items in the Notice of Violation is included in the following.
Violation A 10CFR50.48(b) requires in part that all nuclear power plants licensed to operate prior to January 1, 1979, such as Salem Nuclear Generating Station, Unit 1 shall satisfy the applicable requirements of Appendix R to Part 50, including, specifically, the requirements of Sections III.G, Fire Protection for Safe Shutdown Capability, III. J, Emergency Lighting, and III.O, Oil Collection System for Reactor Coolant Pump.
A.
10CFR Part 50, Appendix R, Section III.G.l requires that fire protection features shall be provided for structures, systems, and components important to safe shutdown.
These features shall be capable of limiting fire damage so that one train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control stations is free of fire damage.
Section III.G.2 and III.G.3 specify alternatives that may be implemented outside of primary containment to assure that one redundant train of equipment, cabling and associated.circuits necessary to achieve and maintain hot shutdown remains free of fire damage.
The alternatives are:
- 1.
Separation of redundant trains of equipment, cabling and associated circuits by a three-hour rated fire barrier.
- 2.
Separation of redundant trains of equipment, cabling and associated circuits by a horizontal distance of 20 feet with no intervening combustibles and fire detection and automatic fire suppression systems installed in the area.
- 3.
Enclosure of redundant trains of equipment, cabling and associated circuits by a one-hour rated fire barrier with fire detection and automatic fire suppression systems installed in the area.
- 4.
Installation of alternative or dedicated shutdown capability independent of the eq~ipment, cabling and associated circuits under consideration, and installation of fire det~ction and fixed fire suppression systems in the area under consideration.
'j..
Contrary to the above, as of January 20, 1984, fire protection features were not provided for certain redundant trains of equipment and/or cabling located outside the primary containment necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control stations such that one train would remain free of fire damage and none of the alternatives provided by Section III.G.2 and III.G.3 were implemented.
Specifically:
- 1.
Redundant charging pumps 11, 12 and 13 in the auxiliary building, 84' elevation, required for hot shutdown were not separated by a three-hour fire barrier and the separation distance was less than 20 feet.
Fire detection was provided; however, the automatic fire suppression was not area wide.
One of the redundant trains was not enclosed in a one-hour fire barrier and no alternative or dedicated shutdown capabilities were provided.
- 2.
The redundant 460 VAC/230 VAC switchgear located in the auxiliary building, 84' elevation, and required for hot shutdown, were not separated by a three-hour fire barrier.
Although the separation distance was greater than 20 feet, there were intervening combustibles consisting of horizontal cable trays and cables.
The installed C02 suppression system was not automatic.
The installed one-hour fire barriers (partial height partitions) between the redundant switchgear did not completely enclose one of the redundant trains and there were no alternative or dedicated shutdown capabilities provided.
- 3.
The redundant service water motor control centers (MCCs) located in the intake structure and required for hot shutdown, were separated by three-hour rated concrete walls.
However, the doors on these walls were not three-hour rated.
The distance between the MCCs was greater than 20 feet and there was fire detection in the area; however, there was no automatic fire suppression.
In addition, neither of the redundant trains were enclosed in a one-hour fire barrier and there were no alternative or dedicated shutdown capabilities provided.
Response to Violation A.l -
Charging Pumps PSE&G does not agree with the violation.
Reason for Disagreement PSE&G disagrees that this constitutes a violation.
By letters dated December 28, 1983 and January 13, 1984, PSE&G identified 'to the NRC that the separation of charging pumps did not conform to the staff's interpretation of Appendix R contained in Generic
Letter 83-33, and requested an exemption from this new interpretation of Appendix R.
PSE&G notified the NRC of this configuration prior to the 1984 inspection.
The additional technical issue referred to in the alleged violation is the lack of area-wide fire suppression.
This issue was taken from Generic Letter 83-33, which has since been rescinded by Generic Letter 86-10.
Generic Letter 86-10 contains the latest NRC interpretations of Appendix R to 10CFR50 and clearly states that complete area-wide suppression is, in fact, not required by Appendix R.
This alleged violation pertains to an issue identified and reported by PSE&G through the exemption process, and also to an issue which the NRC staff has acknowledged in Generic Letter 86-10 is an interpretation of Appendix R that is no longer applicable.
Immediate Corrective Actions and Results Achieved
~~
By letters dated January 13, 1984, January 31, 1985 and January 17, 1986, PSE&G requested an exemption for the configuration of the charging pumps.
As of this date, the staff response to the exemption request has not been provided.
In discussions with the staff reviewers and the NRC Salem Project Manager in late 1986 and early 1987, PSE&G was advised that the likelihood of approval was favorable.
Long Term Corrective Actions Modifications consisting of expanding the sprinkler system to provide full coverage around the charging pumps, as proposed in the exemption request of January 17, 1986, was completed on September 22, 1986.
Compliance Compliance to this rule is subject to NRC approval of PSE&G's exemption request.
Response to Violation A.2 -
460 VAC/230 VAC Switchgear PSE&G does not agree with the violation.
Reason for Disagreement PSE&G disagrees that this constitutes a violation.
The separation of redundant switchgear by partial height marinite board walls was reviewed and approved by the NRC staff during the licensing of Salem Unit 2.
At that time, an NRC team conducted a thorough audit of Unit 2's fire protection program and concluded that the existing program was acceptable for plant operation.
In that Unit 1 and Unit 2 have been treated identically for fire
protection, the Unit 1 program is also considered equally acceptable for plant operation.
In addition, the Appendix R field walkdown conducted at Salem Unit 2 resulted in a request for additional sections to be added to these barriers.
It was PSE&G's belief that the switchgear room was, therefore, a special case, specifically reviewed and inspected by the NRC to the requirements of Appendix R.
Re-review of this issue after the NRC's initial Appendix R inspection was not believed necessary.
In addition, the manually actuated C02 system was the subject of an exemption request dated December 28, 1983 which was reported by PSE&G prior to the January inspection.
The NRC approval of the configuration of the switchgear room in 1981 was apparently voided during the 1984 inspection due to changing staff interpretations and not necessarily due to any failure by PSE&G to comply with a commitment.
Immediate Corrective Actions and Results Achieved By letters dated December 28, 1983, January 31, 1985, and January 17, 1986, PSE&G requested an exemption for complete one hour fire barrier.
The exemption request committed to an automatic suppression system.
Long Term Corrective Actions Upon NRC approval of the exemption request, modifications consisting of upgrading the C02 system with an automatic total flooding fire suppression system, as proposed in the January 17, 1986 exemption request, will be completed.
Compliance Compliance with the rule is subject to NRC approval of PSE&G's exemption request.
Response to Violation A.3 - Service Water Motor Control Centers PSE&G does not agree with the violation.
Reason for Disagreement PSE&G disagrees that this constitutes a violation.
The technical issue that this alleged violation addresses is the lack of a three-hour rated fire door between the redundant service water motor control centers.
This alleged violation is based upon an interpretation of Appendix R contained in Generic Letter 83-33 which has since been rescinded by Generic Letter 86-10.
The revised guidance in Generic Letter 86-10 clearly states that fire area boundaries need not be complete wall-to-wall and floor-to-ceiling barriers to comply with Appendix R.
Further, a licensee may prepare an engineering evaluation to demonstrate the adequacy of incomplete barriers without staff approval.
This notice of violation appears to question compliance to a staff interpretation of Appendix R that is no longer applicable.
Immediate Corrective Actions and Results Achieved By letter dated January 31, 1984, PSE&G requested an exemption for the existing configuration.
By letter dated January 17, 1986, this exemption was withdrawn due to PSE&G's commitment to provide a rated fire barrier between redundant equipment.
Long Term Corrective Actions None.
Compliance Compliance has been achieved by installation of a three hour rated fire door on October 24, 1985.
Violation B 10CFR Part 50, Appendix R, Section III.G.l.b, requires that systems necessary to achieve and maintain cold shutdown from the control room or emergency control station(d) can be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Contrary to the above, as of January 20, 1984, redundant Residual Heat Removal (RHR) pumps (11 and 12) required for cold shutdown were not capable of being repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. as demonstrated by the absence of planning, procedures, and/or materials necessary to implement fire damage repairs.
Response to Violation B-RHR Pumps PSE&G does not agree with the violation.
Reason for Disagreement PSE&G disagrees that this constitutes a violation.
The Notice of Violation states that PSE&G has failed to demonstrate the capability to repair cold shutdown equipment within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. It is PSE&G's belief that this is an incorrect assessment of the RHR system and its use for safe-shutdown.
The Salem Units 1. and 2 shutdown model does not utilize repairs to the RHR system for safe-shutdown.
The Notice of Violation, therefore, does not pertain to the Salem shutdown model.
In addition, by letter dated June 17, 1983, the NRC stated that an exemption to Appendix R is not needed for the RHR heat exchanger area (old fire area PIA-1, new fire areas I-FA-AB-45A &
B) for lack of area-wide suppression and detection
- As stated in Generic Letter 86-10, Appendix R does not require complete rated fire barriers to separate redundant equipment.
In the case of the RHR pumps, an engineering evaluation would be sufficient to demonstrate that the barriers separating the redundant pumps will prevent fire damage to both pumps.
The potential damage to both RHR pumps assumed by the NRC is based upon a staff interpretation in Generic Letter 83-33 which is no longer applicable.
Immediate Corrective Actions and Results Achieved By letters dated January 31, 1984, April 5, 1984 and January 17, 1986, PSE&G requested an exemption from Section III.G of Appendix R for this area.
Long Term Corrective Actions Upon approval of the exemption request, modifications consisting of enhanced penetration seals and fire detection, as proposed in the exemption request of January 17, 1986, will be completed.
Compliance Compliance to the rule is subject to the NRC approval of PSE&G's exemption request.
Violation C 10CFR Part 50, Appendix R, Section III.G.2, requires that, for redundant trainsdof systems necessary to achieve and maintain hot shutdown conditions inside non-inerted containments, one of six (III.G.2.a-f) fire protection means shall be provided.
Contrary to the above, as of January 20, 1984, none of the alternatives {III.G.2.a-f) were satisfied for the pressurizer heater termination cabinet and pressurizer level and pressure instrumentation cabinet 355, which were located inside the primary *containment and relied upon in the fire hazards analysis to achieve and maintain hot shutdown conditions.
Response to Violation C - Pressurizer Heater Cabinet PSE&G does not agree with the violation.
Reason for Disagreement PSE&G disagrees that this constitutes a violation.
Section III.G.2.f of Appendix R to 10CFR50 permits the separation of redundant safe-shutdown equipment inside non-inerted containments by "noncombustible radiant energy shields".
At the time Appendix R was issued, no guidelines were provided to the industry that clearly defined this term.
PSE&G believed that the 10 USSG steel
plate that separated the four sections of Panel 335 formed an adequate radiant energy shield.
(Note that the Notice of Violation refers to Panel 35).
In Generic Letter 86-10, the staff's latest guidance on Appendix R, the NRC acknowledges that non-fire-rated radiant energy shields may be acceptable in certain configurations.
In addition, it is PSE&G's understanding that steel conduits have been approved by the NRC via the exemption process as an acceptable means of separation inside containment.
Due to the above cons*iderations and lack of clarity on what constitutes an acceptable "radiant energy shield", we do not feel that a violation has occurred.
Immediate Corrective Actions and Results Achieved By letters dated January 31, 1985 and January 17, 1986, PSE&G requested an exemption for the configuration of Panel 335.
Long Term Corrective Actions Upon approval of the exemption request, modifications consisting of sprinkler coverage of the panel, as proposed in the January 17, 1986 letter will be completed.
Compliance Compliance with the rule is subject to NRC approval of PSE&G's exemption request.