ML18093A370
| ML18093A370 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 09/18/1987 |
| From: | Corbin McNeil Public Service Enterprise Group |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NLR-N87180, NUDOCS 8709250384 | |
| Download: ML18093A370 (5) | |
Text
-
l Public Service us~tRC-US Electric and Gas t ~ \\>
Company
\\~"\\ $t\\l '2. S A q Corbin A. McNeill, Jr.
Senior Vice President -
Nuclear Public Service Electric and Gas Company P.O. Box236, Hancocks Bridge, NJ 08038 609 339-4800 September 18, 1987 NLR-N87180
- u. s. Nuclear Regulatory Commission Document Control Desk Washington, D. C.
20555 Gentlemen:
10CFR50 APPENDIX R COMPLIANCE SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 This letter addresses the deficiencies id*entified in the Salem Generating Station Fire Protection Program with respect to the applicable requirements of Appendix R and the resultant required compensatory measures.
Also addressed is our commitment to provide the NRC with a detailed evaluation of the subject deficiencies and our management team and effort to assure compliance with Appendix R requirements.
The following deficiencies have been identified:
(a)
With respect to common power source associated circuits, a contractor draft evaluation performed for Salem Units 1 and 2 indicates that breaker coordination may not exist at several voltage levels.
Breaker coordination may not exist for all devices of the following voltage levels:
4KV (without a concurrent loss of offsite power); 460V-230V load centers; 230V motor control centers; 120V AC systems; 125V DC systems; and 28V DC systems.
Breaker coordination currently exists at the 4KV levels for a loss of offsite power Appendix R scenario.
However, for the case where offsite power remains available, the 4KV bus is uncoordinated.
Thus, common power source associated circuits may not conform to the requirement of Section III.G and III.L to 10CFR50 Appendix R.
In that breaker coordination may not exist, a fire t~at impacts cabling associated with an individual power division could result in loss of portions of that power division.
A fire that impacts cabling associated with more than one division could adversely impact the capability to achieve safe shutdown.
1
(b)
The penetration seal program has determined that the test documentation available to justify the installed configuration of penetration seals in rated fire barriers does not adequately envelope all types and configurations of seals in the units.
Additional fire testing and field verification will be conducted to ensure that each penetration seal can be correlated to an acceptable fire test.
In addition, each penetration seal will be labelled and controlled for future inspection and surveillance purposes.
(c)
The radio communication system was originally installed to address the requirements of Appendix A to BTP 9.5.1.
The system design does not meet the requirements of Section III.G of Appendix R in that the power supply originates from the relay room.
A postulated fire* in the Relay Room could result in Control Room evacuation and adversely impact communication system operability.
(d)
The fuel oil storage room 1(2)FA-AB-84D contains redundant cabling for the "B" and "C" train Diesel Generators.
The cables are separated by approximately ?_2 ft. with the major intervening combustible being the fuel oil storage tank.
The "B" Diesel Generator cabling is not completely protected with a one-hour fire barrier.
The area is protected with detection and redundant suppression.
A postulated fire in this area could potentially impact two redundant trains of Diesel Generators.
(e)
The Upper Electrical Penetration Area 1(2)FA-EP-100G contains redundant ventilation cables af f e'Cting room coolers and by association the Diesel Generator fuel oil transfer pumps.
A postulated fire in this area could impact the above noted devices.
(f)
The C02 Equipment Rooms 1{2)FA-DG-84F do not conform to the requirements of Section III.G of 10CFR50 Appendix R.
The area contains cabling for various shutdown systems including Diesel Generators, Service Water System and the Diesel Generator Fuel Oil Transfer Pump.
The cabling for these systems is not protected with a fire barrier, automatic suppression, or detection.
A postulated fire in this area could potentially result in loss of service water and diesel fuel oil transfer capability.
The ability to safely shut down could be adversely impacted.
(g)
In the Auxiliary Building, elevation 64 ft. 1(2)-FA-AB-64B, a single panel {119) contains cabling for redundant residual heat removal {RHR) room coolers.
Thus, this area does not conform to the requirements of Section III.G of 10CFR50 Appendix R.
Fire damage to this panel and associated cabling could potentially result in closure of dampers which support 2
room cooler operation.
In that the cabling for the RHR room ventilation system cooler is not protected by a fire barrier, a postulated fire in this area could adversely impact the ability to achieve and maintain cold shutdown.
(h)
The Pipe Tunnel designated Fire Area 12FA-PT-84 contains redundant cabling for all trains of Unit 2 Service Water Pumps including pump power.
This area is not equipped with detection or automatic suppression.
A postulated fire in this area could potentially result in loss of service water, thereby adversely impacting the ability to achieve and maintain safe shutdown.
(i)
We are presently investigating a concern with a spurious C02 actuation in the Diesel Generator rooms.
The C02 system is actuated for each diesel room by a common fire protection system.
A previous safety evaluation for a single failure concern assumed loss of a diesel on a C02 actuation.
Present procedure requires a diesel to be declared inoperable should the C02 actuate.
We are analyzing the effects of a spurious C02 actuation on Diesel Generator operability.
To compensate for the aforementioned discrepancies:
(1)
Continuous fire watches will be established in the affected areas without detection by 8:00 PM this evening.
Continuous fire watches will be relieved with roving fire watches when/if detection/remote surveillance is established.
(2)
Roving fire watches will be established in all affected areas with operable detection by 8:00 PM this evening.
(3)
The Containment Building temperature will be monitored in the Control Room on an hourly basis in lieu of a fire watch.
The operators will be instructed on specific actions to be taken if containment temperatures rise.
(4)
For areas of high radiation conditions a means of detection/remote surveillance will be evaluated by September 21, 1987.
An implementation date will be agreed upon by the Resident Inspector.
(5)
The backlog of outstanding work orders on fire protection items will be minimized.
We will provide the NRC by October 2, 1987 a detailed safety evaluation of the aforementioned discrepancies in our Appendix R program.
This evaluation will address the operational implications of the deficiencies and resultant compensatory measures.
We propose to meet the week of October 5, 1987 at your Region I office to discuss this submittal.
At that time we 3
will also discuss the breaker coordination program with respect to other internal and external hazards.
PSE&G has established a management team to address the above programmatic and hardware related discrepancies under the direct control of the Manager - Nuclear Engineering Services.
The team is composed of representatives from each functional area including Engineering, Operations, Licensing and Site Protection.
The team is responsible for assuring compliance with Appendix R including the initiation and execution of any temporary compensatory measures necessary to ensure the safe operation of Salem Units 1 and 2.
As the effort progresses we will update you monthly on any additional discrepancies in the Appendix R program.
A schedule for completion of the programmatic and hardware related aspects necessary for Appendix R compliance as well as the above identified discrepancies will be presented at the meeting the week of October 5, 1987.
Should you have any questions on the information herein, please contact us.
Sincerely,
~Z-~~
- c. A. McNeill, Jr.
Senior Vice President -
Nuclear cc:
See next page 4
I cc:
Mr. D. c. Fischer USNRC Licensing Project Manager Mr. T. J. Kenny USNRC Senior Resident Inspector Mr. w. T. Russell, Administrator USNRC Region I Mr. William F. Kane, Director Division of Reactor Projects USNRC Region I Mr. William v. Johnston, Deputy Director Division of Reactor Safety USNRC Region I Mr. Edward c. Wensinger, Chief Projects Branch No. 2 Division of Reactor Projects USNRC Region I Mr. D. M. Scott, Chief Bureau of Nuclear Engineering Department of Environmental Protection 380 Scotch Road Trenton, NJ 08628 5