ML18102B422
| ML18102B422 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 06/30/1997 |
| From: | Eric Simpson Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LR-N97419, NUDOCS 9707090337 | |
| Download: ML18102B422 (3) | |
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1 Company E. C. Simpson Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1700 Senior Vice President - Nuclear Engineering U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 CONTROL AREA AIR CONDITIONING SYSTEM LICENSING BASIS CLARIFICATIONS SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 Gentlemen; On June 10, 1996, Public Service Electric and Gas (PSE&G) submitted a request to amend the Salem Unit 1 and 2 operating licenses to reflect the redesign of the Control Area Air Conditioning System (CAACS). Supplemental information supporting the requested license amendments was provided on June 24, July 1, August 13, September 20 and October 17, 1996. The NRC issued the requested change on February 6, 1997 as Amendments 190 and 173 to the Salem Unit 1 and 2 operating licenses, respectively. PSE&G recently initiated an independent design review of the modifications performed on the CAACS and its subsystem, the control room emergency air conditioning system (CREACS). During this review, an inconsistency in the licensing basis information provided in the June 10, 1996 submittal was identified. The purpose of this submittal is to correct and clarify the licensing basis for the combined CAACS/CREACS.
In Attachment 1 of the June 10, 1996 submittal, PSE&G discussed the use of non-redundant dampers (1(2)CAA14, 17, 20) in the CAACS/CREACS (ref: page 9of18, second paragraph).
Additionally, PSE&G indicated that control room doses could be maintained within General Design Criterion (GDC) 19 limits, provided operator action is taken to manually position a failed damper (ref: page 14of18, second paragraph). This statement is inaccurate in that PSE&G has not prepared a separate dose assessment modeling a damper failure mitigated by operator action.
It is PSE&G's opinion that this scenario goes beyond the NRC approved licensing and design basis, as further discussed below.
The use of non-redundant dampers in the locations described, was retained from the original system design. This configuration was justified during plant licensing on the basis that the non-redundant damper actuators are spring loa. ded to fail to the desired position on loss of control air I or power. The use of non-redundant "fail-safe" dampers was originally approved in the NRC 1
Safety Evaluation Report (SER) dated October 11, 1974 (ref: Section 9.9).
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JUN 3@1997 In the June 10, 1996 submittal PSE&G further justified this configuration on the basis of redundant actuation signals being provided to the damper controls and damper operability verification being performed every 31 days. Given the "fail-safe" design, periodic operability verification and redundant actuation signals, PSE&G concluded that failure of a damper to reposition was unlikely. The continued acceptability of this design was reiterated in Section 2.5 of the NRC SER for Amendments 190 and 173. Specifically, "There are dampers installed on the makeup air supply and return ducts with failure positions consistent with isolation of the [control room envelope] CRE."
To further clarify the discussion presented in Attachment 1 of the June 10, 1996 submittal, PSE&G considers the design of these non-redundant dampers to meet the intent of the Single Failure Criterion as it was applied at the time the Salem units were licensed. Specifically, the dampers will achieve their required positions for the postulated credible failure modes (i.e., loss of control air or power) described in the Updated Final Safety Analysis Report.
Based on the above discussion, PSE&G concludes that the dose assessments submitted in support of Amendments 190 and 173 represent a valid basis for demonstrating compliance with GDC 19.
Those assessments are based on a conservative analytical methodology, the limiting operational configurations for the CAACS/CREACS, and are consistent with the NRC approved licensing and design basis.
NRC concurrence with the basis of this clarification is required prior to July 10, 1997 to support Unit 2 restart. If you have any questions concerning the above, please feel free to contact me directly.
- ... - Decument Control Desk LR-N97419 3
C Mr. H. Miller, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. L. N. Olshan, Licensing Project Manager - Salem U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop l 4E2 l
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Rockville, MD 20852 Mr. C. Marschall (X24)
USNRC Senior Resident Inspector Mr. K. Tosch, Manager, IV Bureau of Nuclear Engineering 33 Arctic Parkway CN415 Trenton, NJ 08625
. JUN.3o1997