ML18096A670
| ML18096A670 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 04/28/1992 |
| From: | Labruna S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLR-N92053, NUDOCS 9205050011 | |
| Download: ML18096A670 (6) | |
Text
Public Service Electric and Gas Company Stanley LaBruna Public Service Electric and Gas Company P.O. Bo~ 236, Hancocks Bridge, NJ 08038 609-339-1200 Vice President - Nuclear Operations APR 2 s 1992 NLR-N92053 U.S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, DC 20555 Gentlemen:
ADDITIONAL INFORMATION -
RECONSIDERATION OF EXEMPTION FROM FIRE PROTECTION REQUIREMENTS SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 Pursuant to your request, dated January 21, 1992, Public Service Electric and Gas Company (PSE&G) has provided, in Attachment 1, our responses to your questions regarding the Control Air System at our Salem plants.
In both the July 20, 1989 NRC denial of our exemption request associated with the fire areas in which each Emergency Control Air Compressor (ECAC) is located and in your latest letter, to which this response is directed, the stated NRC concern is a lack of technical specifications for the ECACs.
On the other hand, PSE&G has maintained in our correspondence that, by virtue of Salem's Control Air System configuration satisfying the criteria of 10 CFR 50, Appendix R, Section III.G.2.a, the ECAC's are not required to be covered by technical specifications.
The crux of this TS issue is providing the necessary assurance of the availability of Control Air.
Resolution of this underlying concern should permit the NRC to grant our outstanding exemption request.
Accordingly, we have provided, in Attachment 2, a discussion the TS issue and proposed actions which, we anticipate, will provide an increased level of assurance for the availability control air and, thereby, a basis for closing this matter.
9205o56of.i-92b4~8-
~DR ADOCK 05000272 PDR of of
Document Control Desk NLR-N92053 2 -
APR 2 ~. 1992 Should you have any questions regarding this submittal, we will be pleased to discuss them with you.
Sincerely, Attachment c
Mr. T. T. Martin, Administrator USNRC Region I Mr. J. Stone USNRC Licensing Project Manager Mr. T. P. Johnson USNRC Senior Resident Inspector Mr. K. Tosch, Chief, Bureau of Nuclear Engineering New Jersey Department of Environmental Protection
MTAaIMENl' 1 RFSroNSE 'IO NRC QUESTIONS gJESTION 1:
How is the availability of control air assured, asstnning a fire disables the o:perating unit's emeJ::gency (control) air compressor? The analysis should comply with and include assumptions as required in 10 CFR Part 50, Appendix R.
RESR:R>E:
Should a postulated fire disable an Emergency control Air Compressor (ECAC) coincident with a loss of off-site power, availability of control air is assured by using the opposite unit's unaffected ECAC which is separated by 3-hour barriers. (The Emergency Control Air system configuration provides redundancy and separation that satisfies Appendix R,Section III.G.2.a criteria). Should off-site power be available, the station air compressor(s),
nonnally running, could satisfy the control air needs of both Salem units -
obviating the need for the opposite unit ECAC.
gJESTION 2:
Provide a list of equipment that requires control air that must be available for:
- a. Achieving and maintaining hot shutdovm,
- b. Transitioning from hot to cold shutdown, and
- c. Maintaining cold shutdown.
RESR:R>E:
The components provided in Tables 1 and 2 list safe shutdown valves which would fail in an undesirable position for supporting an orderly shutdown upon a total loss of control Air. The lists are broken down into achieving and maintaining hot standby and cold shutdown because that is the way we are organized procedurally.
However, hot shutdown is covered in the transition from hot standby to cold shutdown. Since your request for the lists was intended to support the NRC position that technical specifications are necessary for the ECACs, our discussion in Attachment 2 is relevant to this response.
TABLE 1 AIR OPERATED SAFE SHUTDOWN VALVES SALEM GENERATING STATION -
UNIT 1 Hot Standby Mode Component Shutdown Function 1CV71 1CV172 11AF52 12AF52 13AF52 11SW122 12SW376 12SW379 12SW380 12SW383 Chemical Volume & Control Chemical Volume & Control Auxiliary Feedwater Auxiliary Feedwater Auxiliary Feedwater Service Water Service Water Service.Water Service Water Service Water Cold Shutdown Mode Component Shutdown Function 1CV77 Chemical Volume & Control 1CV71 Chemical Volume & Control 1CV4 Chemical Volume & Control 1CV2 Chemical Volume & Control 1CV277 Chemical Volume & Control 1CV7 Chemical Volume & Control 1CV75 Chemical Volume & Control 1CV132 Chemical Volume & control 1CV79 Chemical Volume & control 1CV278 Chemical Volume & Control 1CV131 Chemical Volume & Control 1CC215 Component Cooling 1CC113 Component Cooling Description Control Valve Borate line to Boric Acid Blender Alternate Suction Alternate Suction Alternate Suction 11 Component Cooling Hx Inlet Comp Cool Hx Inlet
- Comp Cool Hx Outlet Comp Cool Hx Inlet Comp Cool Hx Outlet Description Charging Line to 13 Cold Leg Control Valve Regenerative Hx Discharge Regenerative Hx Inlet Regenerative Hx Inlet Letdown Hx Inlet Charging Line to Pressurizer Spray Excess Letdown Outlet Charge Line to 14 Cold Leg Excess Letdown Inlet Excess Letdown Inlet Excess Letdown Hx Supply Excess Letdown Hx Discharge
TABLE 2 AIR OPERATED SAFE SHUTDOWN VALVES SALEM GENERATING STATION -
UNIT 2 Hot Standby Mode Component 2CV71 2CV172 21AF52 22AF52 23AF52 21SW122 Shutdown Function Chemical Volume & Control Chemical Volume & Control Auxiliary Feedwater Auxiliary Feedwater Auxiliary Feedwater Service Water Cold Shutdown Mode Component Shutdown Function 2CV77 Chemical Volume & Control 2CV71 Chemical Volume & Control 2CV4 Chemical Volume & Control 2CV2 Chemical Volume & Control 2CV277 Chemical Volume & Control 2CV7 Chemical Volume & Control 1CV75 Chemical Volume & Control 2CV132 Chemical Volume & Control 2CV79 Chemical Volume & Control 2CV278 Chemical Volume & Control 2CV131 Chemical Volume & Control 2CC215 Component Cooling 2CC113 Component Cooling Description control Valve Borate line to Boric Acid Blender Alternate Suction Alternate Suction Alternate Suction 21 Component Cooling Inlet Description Charging Line to 23 Cold Leg Control Valve Regenerative Hx Discharge Regenerative Hx Inlet Regenerative Hx Inlet Letdown Hx Inlet Charging Line to Pressurizer Spray Excess Letdown Outlet Charge Line to 24 Cold Leg Excess Letdown Inlet Excess Letdown Inlet Excess Letdown Hx Supply Excess Letdown Hx Discharge
J I
DISCUSSION OF 'IECHNICAL SPECIFICATION ISSUE On July 20, 1989, the NRC denied an exenption request associated with the fire areas in which the Emergency Control Air Conpressors (ECAC) are located - due to a lack of Technical Specifications (TS) for those compressors.
In the NRC's Januai:y 21, 1991 letter, the specific concerns regarding the ECAC on one unit are that 11 *** if the opposite unit is in an outage, the emergency control air compressor may not be available." and that, "'!he lack of technical specifications for alternate shutdown capability systems conflict with the guidance issued in Generic Letters 81-12 and 88-12 and will not provide a level of safety equivalent to that achieved by compliance with Appendix R. 11 PSE&G maintains that the Salem ECAC' s meet the redundant equipment and cable 3-hour separation and structural steel protection requirements of 10 CFR 50, Appendix R, section III.G.2.a and are, therefore, not encompassed by the alternate shutdown requirements of Section III.G. 3. It is our interpretation of the guidance of GL 81-12 and GL 88-12, that additional TS recorranended in those documents are only for items that must be addressed under Section III.G.3.
Consequently, we do not believe that we are in conflict with the guidance of the above mentioned Generic Letters.
'Ihrough PSE&G's involvement in the NRC/Industry development of Improved Technical Specifications, we understand that a recent detennination has been made by NRC senior management in a meeting with the Joint OWners Group Executive Advisory Committee which excludes all 10 CFR 50, Appendix R safe shutdown equipment from those specifications. Additionally, in the Federal Register, 57FR4166, dated February 4, 1992, Elimination of Requirements Marginal to Safety, the NRC proposes to eliminate or to make less prescriptive certain regulatory requirements.
Among those regulations which the NRC has identified as having the "highest potential for saving resources without significantly affecting safety margins" are the fire protection requirements of Appendix R.
'lhese NRC decisions and detenninations appear to support PSE&G's position that technical specifications are not necessary for the Salem ECAC's.
However, during our review of the concerns in your letter, we have recognized an opportunity to enhance overall plant reliability and safety, outside of the 10 CFR 50, Appendix R arena, whereby the institution of certain administrative measures at our Salem Units would provide additional assurance of control air availability. 'lhese measures would include the following ECAC maintenance controls:
- No planned maintenance will be perfonned on one ECAC while the opposite unit ECAC is unavailable, and
- All ECAC maintainance will be perfonned under a Priority A Work Order (which is the level of priority attached to equipment covered by technical specifications) to ensure rninirnal outage times on the ECACS.
Since the above measures also add to our assurance of control air availability for the specific set of conditions suggested in your letter, we have included them in this response for your consideration as a resolution to the TS issue.
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