ML18106A805
| ML18106A805 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 08/03/1998 |
| From: | Milano P NRC (Affiliation Not Assigned) |
| To: | Keiser G Public Service Enterprise Group |
| References | |
| TAC-M99875, TAC-M99876, NUDOCS 9808110222 | |
| Download: ML18106A805 (6) | |
Text
Mr. Harold W. Keiser Chief Nuclear Officer & President -
Nuclear Business Unit Public Service Electric & Gas Company Post Office Box 236 Hancocks Bridge, NJ 08038 August 3, ii
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING AUXILIARY BUILDING VENTILATION, SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 & 2 (TAC NOS. M99875 AND M99876)
Dear Mr. Keiser:
In a "LR-N970603, Application for Amends to Licenses DPR-70 & DPR-75,revising Containment Hydrogen Analyzer SRs of [[TS" contains a listed "[" character as part of the property label and has therefore been classified as invalid..1|letter dated October 24, 1997]], as supplemented on January 8, 1998, the Public Service Electric and Gas Company (PSE&G, the licensee) submitted an application for an amendment to the Technical Specifications (TSs) for Salem Nuclear Generating Station, Units 1 and 2. The proposed amendment would modify TS Section 3/4 7.7, "Auxiliary Building Exhaust Air Filtration System."
The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing your submittal and has determined that additional information is required to complete its review. The specific information requested is addressed in the enclosure. The staff requests that the additional information be provided within 45 days of receipt _of this letter.
If you have any questions regarding this matter, please contact me at (301) 415-1457.
Docket Nos. 50-272 and 50-311 Sincerely, Isl Patrick D. Milano, Senior Project Manager Project Directorate 1-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation
Enclosure:
Request for Additional Information cc: See next page DISTRIBUTION:
Docket File PUBLIC PD 1-2 R/F OFFICE PDl-2 DATE 07/ 2<( /98 JZwolinski RCapra TMarsh OFFICIAL RECORD COPY DOCUMENT NAME: SA99875.RAI PMilano RYoung TC lark SPLB/C TMarsh OGC ACRS CHehl, RI l
UNITED STATES NUCLEAR REGULATORY COMMISSION Mr. Harold W. Keiser Chief Nuclear Officer & President -
Nuclear Business Unit Public Service Electric & Gas Company Post Office Box 236 Hancocks Bridge, NJ 08038 WASHINGTON, D.C. 20555-0001 August 3, 1998
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING AUXILIARY BUILDING VENTILATION, SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 & 2 (TAC NOS: M99875 AND M99876)
Dear Mr. Keiser:
In a "LR-N970603, Application for Amends to Licenses DPR-70 & DPR-75,revising Containment Hydrogen Analyzer SRs of [[TS" contains a listed "[" character as part of the property label and has therefore been classified as invalid..1|letter dated October 24, 1997]], as supplemented on January 8, 1998, the Public Service Electric and Gas Company (PSE&G, the licensee) submitted an application for an amendment to the Technical Specifications (TSs) for Salem Nuclear Generating Station, Units.1 and 2. The proposed amendment would modify TS Section 3/4 7.7, "Auxiliary Building Exhaust Air Filtration System."
The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing your submittal and has determined that additional information is required to complete its review. The specific information requested is addressed in the enclosure. The staff requests that the additional information be provided within 45 days of receipt of this letter.
If you have any questions regarding this matter, please contact me at (301) 415-1457.
Docket Nos. 50-272 and 50-311
Enclosure:
Request for Additional Information cc: See next page Sincerely,
~j)~
Patrick D. Milano, Senior Project Manager Project Directorate 1-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation
Mr. Harold W. Keiser Public Service Electric & Gas Company cc:
Jeffrie J. Keenan, Esquire Nuclear Business Unit-N21 P.O. Box236 Hancocks Bridge, NJ 08038 General Manager - Salem Operations Salem Nuclear Generating Station P.O. Box236 Hancocks Bridge, NJ 08038 Mr. Louis Storz Sr. Vice* President - Nuclear Operations Nuclear Department P.O. Box236 Hancocks Bridge, NJ 08038 Senior Resident Inspector Salem Nuclear Generating Station U.S. Nuclear Regulatory Commission Drawer0509 Hancocks Bridge, NJ 08038 Dr. Jill Lipoti, Asst. Director Radiation Protection Programs NJ Department of Environmental Protection and Energy CN 415 Trenton, NJ 08625-0415 Maryland Office of People's Counsel 6 St. Paul Street, 21st Floor Suite 2102 Baltimore, MD 21202 Ms. R. A. Kankus Joint Owner Affairs PECO Energy Company 965 Chesterbrook Blvd., 63C-5 Wayne, PA 19087 Mr. Elbert Simpson
- Senior Vice President-Nuclear Engineering Nuclear Department P.O. Box 236 Hancocks Bridge, NJ 08038 Salem Nuclear Generating Station, Units 1and2 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 Manager-Licensing and Regulation Nuclear Busienss Unit-N21 P.O. Box 236
- Hancocks Bridge, NJ 08038 Mr. David Wersan Assistant Consumer Advocate Office of Consumer Advocate 1425 Strawberry Square Harrisburg, PA 17120 Manager - Joint Generation Atlantic Energy 6801 Black Horse Pike Egg Harbor Twp., NJ 08234-4130 Carl D. Schaefer External Operations - Nuclear Delmarva Power & Light Company P.O. Box231 Wil~ington, DE 19899 Public Service Commission of Maryland Engineering Division Chief Engineer 6 St. Paul Centre Baltimore, MD 21202-6806
REQUEST FOR ADDITIONAL INFORMATION AUXILIARY BUILDING VENTILATION SALEM NUCLEAR GENERATING STATION, UNITS 1AND2
- 1.
On page 3 of the license change request (LCR) dated October 24, 1997, the licensee states:
"On a safety injection (SI) signal the non-operating exhaust fan will automatically l?tart to maximize flow. Alteration of this default configuration to optimize system performance requires manual intervention. In addition, dampers that normally direct effluent from the emergency vent duct through the HEPA filters are manually shifted during accident conditions to include air flow through the carbon adsorber unit."
With regard to the execution of manual actions under accident conditions as noted above, are such actions executed from the Control Room or in areas that result in radiological exposure of plant personnel? How have these manual actions been accounted for in accident dose analysis?
- 2.
On page 9.4-10 of the SGS-UFSAR, it states: "The Auxiliary Building Ventilation System continuously maintains the building at a slight negative pressure with respect to outdoors." In Insert B(e) for the proposed TS LCO, the licensee states in part: "With Auxiliary Building pressure at or above zero inches water column (0.00" wg) with respect to atmospheric pressure......... "
In accordance with Westinghouse Standard TS (WOG-STS), the Auxiliary Building Ventilation System (ABVS) should maintain the building at a specific negative pressure (e.g., -0.125 (1/8) inches water gauge with respect to atmospheric pressure). (For example, see WOG-STS 3.7.12 and 3.7.13.) The system should also maintain a negative pressure with respect to building adjacent areas. The proposed TS should be revised to specify negative pressure with respect to adjacent areas. If not, explain.
- 3.
ABVS alignment appears to indicate that part of effluent flow out the plant vent is not being filtered by the charcoal filter during emergency operations. How does the licensee ensure that contaminated air inside the ECCS areas does not flow out the plant vent unfiltered? (See page 9.4-8 of SGS-UFSAR and Insert J for proposed TS bases.)
- 4.
Temperature and relative humidity should be specified for laboratory analysis of a representative carbon sample to demonstrate the removal efficiency of iodine. The proposed TS should be revised to specify the standard used in obtaining laboratory samples.
ASTM D3803-1989 only specifies the testing of laboratory samples for organic methyl iodine, not elemental iodine as specified in the proposed TS. Methyl iodine had been used in the Salem TS before the proposed TS revision. Because the exact composition of the source term can vary depending on the accident scenario, the staff believes that organic methyl iodine, as. specified in ASTM D3803-1989, should be used because the removal efficiency for methyl iodine will bound that for elemental iodine.
(The above applies to Inserts C(b)(S) and D(c) for th*e proposed TS.)
I
- 5.
In Insert C(b)(6) for the pro-posed TS surveillance requirements (SRs), the licensee states:
"Verifying that flow rate through the carbon adsorber does not exceed 23,540 cfm (21,400 cfm + 10%) when either HEPA plus carbon adsorber combination is aligned to the ECCS areas."
The flow rate through the carbon adsorber should be specified as "21,400 cfm plus or
- minus 10 percent" ratherthan the maximum flow rate (21,400 cfm + 10%) only. Flow rate plus or minus 1 O percent has been used elsewhere in the proposed TS SRs.
Otherwise, explain the basis for the difference.
- 6.
In Insert D(e) for the proposed TS SRs, the licensee states:
"After any structural maintenance on the HEPA or carbon adsorber unit mounting frames or housing, perform tests as required by surveillance 4.7.7.1 (b)(3) and 4.7.7.1 (b)(4)."
Should this SR [D(e)] specify the SRs as provided by Inserts C(b)(1) through C(b)(4) for the proposed TS?
- 7.
Inserts C(b)(1) and C(b)(2) should specify the standards to which the verifying tests are performed (e.g., ANSl/ASME N510, etc.). Otherwise, explain*.
- 8.
On page 5 of the LCR, the licensee states:
"For conditions where two or three exhaust fans are inoperable, uncontrolled releases of particulate and gaseous contamination from the Auxiliary Building could occur under post LOCA conditions due to the inability to maintain negative Auxiliary Building pressure.
However, PSG&E believes that the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed outage time is appropriately -
conservative due to...... "
For the case where all (2) supply fans are inoperable, the proposed action statement would require that the unit be placed in Hot Standby within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> since post-accident design-basis temperatures can not be assured in the Auxiliary Building.
Explain further the rati<;male for usage of the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed outage time (AOT) for the case where all (3) exhaust fans are inoperable.
- 9.
On page 6 of the LCR, the licensee states:
"For the changes contained in the proposed Surveillance Requirements 4.7.7.1 (b)(1) and
- 4. 7. 7.1 (b)(2), PSE&G altered the manner in which the 18 month test is performed.
Specifically, PSE&G would like to replace DOP with halogenated hydrocarbon refrigerant as the challenge agent when determining total system bypass."
Explain further the basis for requesting changes in the 18 month SR test (e.g., a comparison of DOP versus halogenated hydrogen carbon as the challenge agent for total system bypass). Also, clarify the purpose for the proposed SR test and how this test compares with past practices (e.g., the invasive practice of removing and reinstalling HEPA filters to ensure that they do not bias the test results).
\\
3 -
- 10.
On page 8 of the LCR, the licensee states:
uFor the changes contained in the proposed Surveillance Requirement 4.7.7.1(f) and
- 4. 7. 7.1 (g), PSE&G is providing requirements to ensure proper testing of the carbon adsorber unit after flow from the normal areas of the Auxiliary Building or the containment purge has been directed through the carbon adsorber. The airflows from these areas exceed the capacity of the carbon filter and therefore verification of the carbon adsorber operability is required.*
Explain how airflow from the normal areas (Auxiliary Building or containment purge) exceeds the capacity of the carbon filter which requires verification of carbon adsorber integrity and operability.
- 11.
After reviewing your submittal as well as information from the Salem Individual Plant Examination (IPE) and other documents to evaluate the risk impact of the proposed changes, the following information is required:
- a.
According to the Salem IPE, the ABVS supports the operation of the Safety Injection pumps, RHR pumps, AFW pumps, CCW pumps, Charging pumps, and Containment Spray pumps. The IPE assumes that these pumps do not require ABVS during the mission time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Justify this assumption by summarizing your technical bases.
- b.
Is your current PRA the same as the IPE? If no, is the assumption still the same in your current PRA? Explain.
- c.
Explain, quantitatively or qualitatively, what the risk impact of the proposed changes in ABVS would approximately be small in terms of both core damage frequency and large early release frequency. Provide the result of the sensitivity or uncertainty analyses, if any, associated with the ABVS.