ML18094B267
| ML18094B267 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 01/23/1990 |
| From: | Crimmins T Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-88-17, NLR-N89199, NUDOCS 9002050297 | |
| Download: ML18094B267 (4) | |
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Public Service Electric and Gas Company Thomas M. Crimmins, Jr.
Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4700 Vice President - Nuclear Engineering JAN 2 3 1990 NLR-N89199
- u. s. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
REQUEST FOR DEFERRAL OF PLANNED MODIFICATIONS SALEM GENERATING STATION UNIT NO. 2 DOCKET NO. 50-311 In order to better utilize available resources during the upcoming Unit 2 fifth refueling outage, PSE&G proposes to defer implementation of two modifications committed to in PSE&G's response to Generic Letter 88-17 dated January 27, 1989.
The specific items and basis for their deferral are presented below.
Items to be Def erred PSE&G hereby proposes to defer the following Unit 2 modifications from the fifth refueling outage to the sixth refueling outage.
- 1)
In order to improve the capability to monitor Decay Heat Removal (DHR), RHR system parameters will be added to the system upon which the Safety Parameter Display System (SPDS) resides.
- 2)
Generic Letter 88-17 states that plastic tubing may not be accepted as an instrumentation component.
Tygon tubing is presently used for local RCS level indication.
This local indication serves as a means of verifying control room RCS level indication, redundant to the channel checks and calibration.
PSE&G is committed to upgrading the existing level indication design, and is currently evaluating alternatives that will meet the intent of the Generic Letter 88-17 commitment.
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Document Control Desk NLR-N89199 Basis for Deferral Decay Heat Removal Monitoring Capability JAN 2 3 1990)
PSE&G is in the process of implementing a SPDS action plan, as described in response to Generic Letter 89-06.
The purpose of the action plan is to bring the SPDS into full compliance with NUREG 0737, Supplement 1 requirements.
The action plan is scheduled for completion by March 31, 1990.
As part of a longer term upgrade of SPDS, software and hardware modifications beyond the scope of the Generic Letter 89-06 action plan are being implemented.
New software, with accompanying source codes, will be utilized.
Benchmark testing of the new software will be more extensive than that performed for the original software.
New hardware will be installed in order to allow a smooth transition from the current system to the new system.
The present schedule for this scope of work targets completion consistent with the Unit 1 ninth refueling outage schedule (fourth quarter 1990).
Deferral of the modification to add DHR parameters to the SPDS host computer will allow the cognizant personnel to focus their resources on the action plan and long term upgrade described above.
The deferral would also avoid having to install DHR monitoring capability compatible with the existing SPDS system and then modify it coincident with the SPDS upgrade.
PSE&G will be working on two additional TMI related modifications during the fifth refueling outage.
This work places an additional burden on the resources needed to install the DHR monitoring capability:
o For the Subcooling Margin Monitor (SMM), redundant microprocessors will be added.
They will provide two independent subcooling margin indications in the control room.
PSE&G originally proposed implementing the SMM modifications during the sixth refueling outage.
At the request of the NRC, it will be done during the fifth outage.
o Phase II of the Control Room Design Review (CRDR) Modification Project will be implemented.
Due to the 10 CFR Part 21 Report issued for indicators manufactured by the Bailey Controls Co, Phase II will include replacement of Bailey instrumentation with Dixson instrumentation.
Work associated with these
Document Control Desk NLR-N89199
- JAN 2 3 1990 indicators was originally scheduled to be completed during Unit 2's fourth refueling outage (i.e., CRDR Phase I).
Phase II will also include correction of labeling inconsistencies, installation of control console connections needed for future Salem switchyard instrumentation and correction of selected Human Engineering Deficiencies (HEDs) previously identified during the Control Room Design Review.
Replacement of Tygon Tubing The two independent RCS loop flow transmitters presently used for RCS level indication in the control room meet the guidance of Generic Letter 88-17 and provide the primary indication of RCS level during refueling operations.
The transmitters undergo channel checks and calibration independent of the local level indication provided by the tubing.
The local indication is a redundant and diverse means of verifying accuracy of the control room indication and is used only for brief periods during shutdown operations.
An operator is present whenever it is in use in the event that the tubing requires manual isolation.
Therefore, PSE&G believes that postponing the modification until the sixth Unit 2 refueling outage will not have any adverse safety significance.
PSE&G's Generic Letter 88-17 response identified an evaluation of the need for an additional RHR system vent path as an enhancement to DHR reliability.
The benefits of installing a new vent path were evidenced during the loss of RHR event at Salem Unit 1 on May 20, 1989 (subsequent to the Generic Letter response).
The additional vents are scheduled for installation during the fifth refueling outage for Unit 2 and the ninth outage for Unit 1.
PSE&G's position is that dedicating time and resources to the vent installation rather than replacing the tygon tubing results in a greater safety benefit and further justifies deferring the latter modification.
Summary Resource constraints limit the amount of work that may reasonably be performed in a given area during a single refueling outage.
PSE&G assigns the SPDS upgrade and action plan, SMM, CRDR and RHR vent path modifications a higher safety significance than the modifications proposed for deferral.
PSE&G therefore believes that the deferral of the DHR monitoring enhancements and RCS level indication upgrade to the Unit 2 sixth refueling outage is justified.
Document Control Desk NLR-N89199
- JAN 2 3 199@
If there are any questions regarding this letter please do not hesitate to contact us.
c Mr. J. c. stone Licensing Project Manager
- Mr. T. Johnson 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