ML18094A558
| ML18094A558 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 07/05/1989 |
| From: | Stone J Office of Nuclear Reactor Regulation |
| To: | Miltenberger S Public Service Enterprise Group |
| References | |
| GL-88-17, TAC-69771, TAC-69772, NUDOCS 8907130375 | |
| Download: ML18094A558 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 Docket Nos. 50-272/311 Mr. Steven E. Miltenberger Vice President and Chief Nuclear Officer Public Service Electric & Gas Company Post Office Box 236 Hancocks Bridge, New Jersey 08038
Dear Mr. Miltenberger:
July 5, 1989
SUBJECT:
COMMENTS ON THE PUBLIC -SERVICE ELECTRIC AND GAS COMPANY RESPONSE TO GENERIC LETTER 88-17 WITH RESPECT TO EXPEDITIOUS ACTIONS FOR LOSS OF DECAY HEAT REMOVAL (TAC NOS. 69771/69772)
RE:
SALEM GENERATING STATION, UNIT NOS. 1 AND 2 Generic Letter (GL) 88-17 was issued on October 17, 1988 to address the potential loss of decay heat removal (DHR) during nonpower operation.
In the GL, we requested (1) a description of your efforts to implement the eight recommended expeditious actions of the GL and (2) a description of the enhancements, specific plans and a schedule for implementation of the six recommended program enhancements.
The NRC staff has reviewed your response to Generic Letter 88-17 on.expeditious actions in your letter of January 6, 1989.
We find that it appears to meet the intent of the GL but lacks some of the details requested in Enclosure 2 of GL 88-17.
Your response to some items is brief and therefore does not allow us to fully understand your actions taken in response to GL 88-17.
You may wish to consider several observations in order to assure yourselves that the actions are adequately addressed:
- 1.
You indicate that administrative controls have been developed and procedures are in place to reasonably assure that containment closure can be achieved within the time at which core uncovery could result from a loss of DHR coupled with an inability to initiate alternate cooling or addition of water to the RCS inventory.
You state the estimated time for closure of the equipment hatch using a polar crane is 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Therefore, you procedurely require that the hatch remain closed during mid-loop operation, unless the core will remain covered for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> if RHR is lost.
As noted in Generic Letter 88-17 there are conditions in which the containment closure will need to be made within 30 minutes for Westinghouse plants. This is when there are vent areas totaling greater than one square inch in the cold leg (see Section 2.2.2 of GL 88-17). Although you state that the equipment hatch will be kept closed, you should be aware of conditions that may lead to quick core uncovery and be prepared, if required, to address the need for quickly closing other paths such as the personnel hatch, piping and electrical openings.
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\\~ 2.
You indicate that two RCS level indications, from transmitters located on th~. intermediate leg, are available per unit in the contra l room.
These provide continuous indication in the control room with an alarm set for 6 inches above the centerline level. The level indication is also input to the plant computer and recorder for trending. The readings are logged hourly in the control room.
The range and accuracy of these two level instruments are not provided. Also, the reference pressure vent location is not stated. The pressure of the reference leg should approximate the pressure of the void in the hot leg or be compensated to obtain the correct level value.
You state that you also have a tygon tube level instrument which is connected to the No. 3 intermediate leg drain connection and is vented to the containment.
When two or more level instruments are in place, care should be taken to resolve any discrepancy between the measurement systems.
- 3.
You have indicated that your procedures require backup means for adding inventory to the RCS when operating in a reduced inventory condition.
One high head charging/safety injection pump is to be operable (per Technical Specification 3.1.2.3) and one intermediate head safety injection pump is to be available (administratively tagged for the shift supervisor).
You state that an additional alternative is gravity feed.
When using gravity feed a proper means for venting must be in place and verified by calculations.Jsee next item).
- 4.
For gravity feed, a hot leg vent is needed whenever the RCS is in a reduced inventory condition. The removal of a pressurizer manway or steam generator manway is a means to provide RCS venting.
- However, calculations need to be performed to verify the effectiveness of RCS openings because, even for relatively large hot side openings in the RCS, pressurization to several psi can still result. For example, with removal of a pressurizer manway, ;large steam flows in combination with flow restrictions in the surge line and lower pressurizer hardware may still lead to pressurization.
- 5.
Regarding the use of nozzle dams, you state that if all 4 steam generators need to have their hot and cold legs closed by nozzle dams, a minimum 0.5 square foot opening is required to provide an adequate vent path.
You have also discussed the use of steam generators (SGs)* for cooling and thus reducing pressure (i.e., not all steam generators have dams in place). You state that in the worst case scenario, 3 safety valves would need to be removed for an adequate vent path, but that the vent path could be significantly reduced if 2 steam generators (normally maintained available) were used.
In. this case you state that PORVs would provide a more than adequate vent path.
An adequate vent area should be based on a plant specific analysis based on the decay heat loads for the time considered *. In the use of steam generators, there is no follow-up in your discussion to indicate that there would be provisions for making sure water was in the secondary side of the steam generators and that steam could be relieved on the secondary side.
. There is no need to respond to the above observations.
As you are aware, the expeditious actions you have briefly described are an interim measure to achieve an immediate reduction in risk associated with reduced inventory operation. These will be supplemented and in some cases replaced by programmed enhancements.
We intend to audit both your response to the expeditious actions and your programmed enhancement program.
The areas where we do not fully understand your responses as indicated above may be covered in the audit of expeditious actions.
This closes out the staff review of your responses to the expeditious actions listed in the GL.
The area of programmed enhancements will be addressed in a separate letter.
cc: See next page Sincerely,
~ck James C. Stone, Project Manager Project Directorate I-2 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation
.-: "' There is no need to respond to the above observations.
As you are aware, the expeditious actions you have briefly described are an interim measure to achieve an immediate reduction in risk associated with reduced inventory operation. These will be supplemented and in some cases replaced by programmed enhancements.
We intend to audit both your response to the expeditious actions and your programmed enhancement program.
The areas where we do not fully understand your responses as indicated above may be covered in the audit of expeditious actions.
This closes out the staff review of your responses to the expeditious actions listed in the GL.
The area of programmed enhancements will be addressed in a separate letter.
cc: See next page DISTRIBUTION Docket File NRC PDR/LPDR PDI-2 Reading SVarga BBoger WButler MO'Brien JS tone MThadani OGC EJordan BGrimes ACRS (10)
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Sincerely,
/SI James C. Stone, Project Manager Project Directorate I-2 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation PDI-2/D lf?
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Mr. Steven E. Miltenberger eublic Service Electric I Gas Company cc:
Mark J. Wettertiahn, Esquire Conner and Wetterhahn Suite 1050 1747 Pennsylvania Avenue, NW Washington, DC 20006 Richard Fryling, Jr., Esquire Law Department - Tower SE 80 Park Place Newark, NJ 07101 Mr. L. K. Miller General Manager - Salem Operations Salem Generating Station P.O. Box 236 Hancocks Bridge, NJ 08038 Mr. S. LaBruna Vice President - Nuclear Operations Nuclear Department P.O. Box 236 Hancocks Bridge, New Jersey 08038 Robert Traee, Mayor Lower Alloways Creek Township Muni cipa 1 Ha 11 Hancocks Bridge, NJ 08038 Kathy Halvey Gibson, Resident Inspector Salem Nuclear Generating Station U.S. Nuclear Regulatory Co11111iss1on Drawer I Hancocks Bridge, NJ 08038 Richard F. Engel Deputy Attorney General Department of Law and Public Safety CN-112 State House Annex Trenton, NJ 08625 Mr. Kent Tosch, Chief New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering State of New Jersey CN 415 Trenton, NJ 08625 Salem Nuclear Generating Station Richard* a. McGlynn, CoB1Tiission Department of Public Utilities State of New Jersey 101 Co11111erce Street Newark, NJ 07102 Regional Administrator, Region I U. S. Nuclear Regulatory ColTITlission 475 Allendale Road King of Prussia, PA 19406 Lower Alloways Creek Township c/o Mary O. Henderson, Clerk Municipal Building, P.O. Box 157 Hancocks Bridge, NJ 08038 Mr. Bruce A. Preston, Manager Licensing and Regulation Nuclear Department P.O. Box 236 Hancocks Bridge, NJ 08038 Mr. David Wersan Assistant Consumer Advocate Office of Consumer Advocate 1425 Strawberry Square Harrisburg, PA 17120 Scott B. Ungerer MGR. - Joint Generation Projects Atlantic Electric P:o. Box 1500 1199 Black Horse Pike Pleasantville, NJ 08232 Delmarva Power & Light Company c/o Jack Urban General Manager, Fuel Supply 800 King Street P.O. Box 231 Wilmington, DE 19899