ML18094A579
| ML18094A579 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 07/17/1989 |
| From: | Mitenberger S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-NUREG-1022 NLR-N89074, NUDOCS 8907210073 | |
| Download: ML18094A579 (2) | |
Text
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- '.tr Public Service Electric and Gas Company Steven E. Miltenberger Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4199 Vice President and Chief Nuclear Officer July 17, 1989 NLR-N89074 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
REPORTABILITY OF POPS EVENTS SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50~311 The purpose of this letter is to request agreement with an interpretation of Technical Specification 3.4.10.3, "Overpressure Protection Systems". **This specification requires that any actuation of the Pressurizer overpressure Protection system (POPS) be reported to the NRC via a special report.
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several times in the past, a.~pecial report has been required as a result of normal plant operating procedures.
This occurs_
during plant fill-and-vent operations following draindowns for refueling or other reasons.
During the fill-and-vent process, plant procedures require "bumping" the Reactor Coolant Pumps *
(RCPs) to circulate trapped gasses to the reactor high points for venting.
The pressure surge from the "bumping" operation has caused actuation of the POPS.
This actuation is caused by the initial surge of the RCS coolant in the non-vented, non-solid system.
The RCS fill and vent procedure contains an advisory that this operation may ~esult* in a POPS actuation.
PSE&G has investigated the potential for expanding the operational band to alleviate this problem.
currently, the POPS lift setpoint is 375 psig and cannot be increased without reducing the safety margin incorporated into the calculations.
Likewise, the RCP operation limit, 325 psig, cannot be reduced due to pump seal concerns.
PSE&G believes that the intent of the reporting requirement is to advise the NRC and industry of significant operational events that challenge the integrity of the Reactor Vessel and that require actuation of the POPS to mitigate these events, and was not intended to cover planned and self limiting operations such as occur during the fill-and-vent procedure.
PSE&G believes that the issuance of a special report under these planned and self limiting circumstances is not warranted.
This position is
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7-17-89 supported by NUREG 1022, Appendix c in an example that stated if a trip was part of the preplanned sequence during testing or operation then it need not be reported.
This is similar to the situation described above in that the activation of the POPS is anticipated and addressed in plant operating procedures.
Should you have any questions, please feel free to contact us.
c Mr. J. c. stone Licensing Project Manager Ms. K. Halvey Gibson Senior Resident Inspector Sincerely, Mr. w. T. Russell, Administrator Region I Mr. Kent Tosch, Chief New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625