ML18096A858

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Advises That 901221 & 910620 Response to Generic Ltr 90-06 Do Not Meet 10CFR50.109 Requirements & Unacceptable.Requests That Response Be Resubmitted
ML18096A858
Person / Time
Site: Salem  PSEG icon.png
Issue date: 07/24/1992
From: Stone J
Office of Nuclear Reactor Regulation
To: Miltenberger S
Public Service Electric & Gas Co, of New Jersey
References
GL-90-006, REF-GTECI-070, REF-GTECI-094, REF-GTECI-NI, TAC-77448, TAC-M77374, TAC-M77375, TAC-M77447, TASK-070, TASK-094, TASK-70, TASK-94, TASK-OR NUDOCS 9207310064
Download: ML18096A858 (4)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 Docket Nos. 50-272 and 50-311 Mr. Steven E. Miltenberger Vice President and Chief Nuclear Officer Public Service Electric and Gas Company Post Office Box 236 July 24, 1992 Hancocks Bridge, New Jersey 08038

Dear Mr. Miltenberger:

SUBJECT:

STAFF REVIEW OF GENERIC LETTER 90-06, "RESOLUTION OF GENERIC ISSUE 70, 'POWER-OPERATED RELIEF VALVE AND BLOCK VALVE RELIABILITY,' AND GENERIC ISSUE 94, 'ADDITIONAL LOW-TEMPERATURE OVERPRESSURE PROTECTION FOR LIGHT-WATER REACTORS,' PURSUANT TO 10 CFR 50.54(f)",

SALEM NUCLEAR GENERATING STATION, UNITS 1 AND 2 (TAC NOS. M77374, M77375, M77447 AND M77448)

By lette~s dated December 21, 1990 and June 20, 1991, Publtc Service Electric and Gas Company (PSE&G), responded to Generic Letter 90-06.

The generic letter represented the technical resolution of two generic issues and included plant backfits which were cost-justified safety enhancements.

Generic Issue 70 included upgrades in quality requirements, inservice testing requirements, and modified technical specifications for all pressurized water reactor facilities that incorporate PORVs and block valves in their design.

The intended purpose was to enhance the overall reliability of the PORVs and block valves so that they could better perform the safety functions identified in the generic letter. Generic Issue 94 included modified technical specifications fpr all Westinghouse and Combustion Engineering facilities to reduce the allowed outage time for an inoperable LTOP channel and thus reduce the probability of overpressurization events during shutdown conditions.

The staff has reviewed your submittals and finds that you have deviated from the model technical specification included in the generic letter. It is the staff's position that a regulatory analysis has been performed in accordance with 10 CFR 50.109(a)(3) and 50.109(c) which justifies the backfit.

Therefore, absent any informatibn that demonstrates that your facility is not bounded by the regulatory analysis that accompanied the generic letter, you are requested to resubmit a response that is in keeping with the intent of the generic letter. The specific areas of concern are as follows.

Mr. Steven July 24, 1992 As discussed in NUREG-1316, most of the safety enhancement for the proposed backfit is derived from the increase in feed and bleed capability. Therefore, for those facilities that can accomplish the three safety functions identified in the generic letter without relying on PORVs for the feed and bleed function, the allowed outage time (AOT) for an inoperable PORV (for reasons other than excessive leakage) may be increased from the recommended 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days.

The staff's position is that a change in allowed outage times based solely on a PRA argument is not acceptable.

Only differences in plant hardware relative to that assumed in the staff's cost/benefit analysis will be considered.

Therefore, based on the additional guidance provided above, you are requested to resubmit your response to the generic letter within 60 days following receipt of this letter.

If you would like to further discuss these issues prior to your resubmittal, please feel free to contact me.

  • cc:

See next page

. DISTRIBUTION:

Docket File NRC & Local PDRs PDI-2 Reading

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. NAME MO'Brien(2)

JStone OGC DPickett RFrahm GHammer PDI-2/P Sincerely,

/SI James C. Stone, Senior Project Manager Project Directorate I-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation ACRS(lO)

EWenzinger, RGN-I JWhite, RGN-I PDI-2/D I I

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Mr. Steven July 24, 1992 As discussed in NUREG-1316, most of the safety enhancement for the proposed backfit is derived from the increase in feed and bleed capability. Therefore, for those facilities that can accomplish the three safety functions identified in the generic letter without relying on PORVs for the feed and bleed function, the allowed outage time (AOT) for an inoperable PORV (for reasons other than excessive leakage) may be increased from the recommended 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days.

The staff's position is that a change in allowed outage times based solely on a PRA argument is not acceptable.

Only differences in plant hardware relative to that assumed in the staff's cost/benefit analysis will be considered.

Therefore, based on the additional guidance provided above, you are requested to resubmit your response to the generic letter within 60 days following receipt of this letter.

If you would like to further discuss these issues prior to your resubmittal, please feel free to contact me.

cc:

See next page Sincerely,

~c.~

James C. Stone, Senior Project Manager Project Directorate 1-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation

Mr. Steven E. Miltenberger Public Service Electric & Gas Company cc:

Mark J. Wetterhahn, Esquire Winston & Strawn 1400 L Street NW Washington, DC 20005-3502 Richard Fryling, Jr., Esquire Law Department - Tower 5E 80 Park Place Newark, NJ 07101 Mr. Calvin A. Vondra 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 Mr. Thomas P. Johnson, Senior Resident Inspector Salem Generating Station U.S. Nuclear Regulatory Commission Drawer I Hancocks Bridge, NJ 08038 Dr. Jill Lipoti, Asst. Director Radiation Protection Programs NJ Department of Environmental Protection CN 415 Trenton, NJ 08625-0415 Maryland People's Counsel American Building, 9th Floor 231 East Baltimore Street Baltimore, Maryland 21202 Mr. J. T. Robb, Director Joint Owners Affairs Philadelphia Electric Company 955 Chesterbrook Blvd., 51A-13 Wayne, PA 19087 Salem Nuclear Generating Station, Units 1 and 2 Richard Hartung Electric Service Evaluation Board of Regulatory Commissioners 2 Gateway Center, Tenth Floor Newark, NJ 07102 Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Lower Alloways Creek Township c/o Mary 0. Henderson, Clerk Municipal Building, P.O. Box 157 Hancocks Bridge, NJ 08038 Mr. Frank X. Thomson, Jr., 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 Mr. J. A. Isabella MGR. - Generation Department Atlantic Electric Company P.O. Box 1500 1199 Black Horse Pike Pleasantville, NJ 08232 Carl D. Schaefer External Operations - Nuclear Delmarva Power & Light Company P.O. Box 231 Wilmington, DE 19899 Public Service Commission of Maryland Engineering Division ATTN:

Chief Engineer 231 E. Baltimore Street Baltimore, MD 21202-3486