ML20078R235
| ML20078R235 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 02/13/1995 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | Public Service Enterprise Group |
| Shared Package | |
| ML20078R239 | List: |
| References | |
| NUDOCS 9502220272 | |
| Download: ML20078R235 (6) | |
Text
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7590-01 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
PUBLIC SERVICE ELECTRIC AND
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Docket Nos. 50-272 AND GAS COMPANY
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and 50-311
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(Salem Nuclear Generating
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Station, Units 1 and 2
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EXEMPTION 1.
The Public Service Electric and Gas Company (the licensee) is the holder of Facility Operating License Nos. DPR-70 and DPR-75, which authorize operation of the Salem Nuclear Generating Station, Units 1 and 2, respectively. The licenses provide, among other things, that the licensee is subject to all rules, regulations, and orders of the Commission now or hereafter in effect.
The facilities consist of two pressurized water reactors, Salem Nuclear Generating Station, Units 1 and 2, at the licensee's site located in Salem, New Jersey.
II.
In its letter datcd December 22, 1994, the licensee requested an exemption from the Commission's regulations. Title 10 of the Code of Federal Regulations, Part 50, Section 60 (10 CFR 50.60), " Acceptance Criteria for Fracture Provention Measures for Light-water Nuclear Power Reactors for Normal Operation," states that all light-water nuclear power reactors must meet the fracture toughness and material surveillance program requirements for the reactor coolant pressure boundary as set forth in Appendices G and H to 10 CFR 9502220272 95<M213 PDR ADOCK 05000272 P
pm
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t ;
Part 50. Appendix G to 10 CFR Part 50 defines pressure / temperature (P/T) limits during any condition of normal operation, including anticipated operational occurrences and system hydrostatic tests to which the pressure boundary may be subjected over its service lifetime.
It is specified in 10 CFR 50.60(b) that alternatives to the described requirements in Appendices G and H to 10 CFR Part 50 may be used when an exemption is granted by the Commission under 10 CFR 50.12.
To prevent low temperature overpressure transients that would produce pressure excursions exceeding the Appendix G P/T limits while the reactor is operating at low temperatures, the licensee installed a low temperature overpressure (LTOP) system. The system includes pressure-relieving devices called Power-0perated Relief Valves (PORVs). The PORVs are set at a pressure low enough so that if an LTOP transient occurred, the mitigation system would prevent the pressure in the reactor vessel from exceeding the Appendix G P/T limits.
To prevent the PORVs from lifting as a result of normal operating pressure surges (e.g., reactor coolant pump starting, and shifting operating charging pumps) with the reactor coolant system in a water solid condition, the us ating pressure must be maintained below the PORV setpoint.
In addition, in order to prevent cavitation of a reactor coolant pump, the operator must maintain a differential pressure across the reactor coolant pump seals. Hence, the licensee must operate the plant in a pressure window that i
is defined as the difference between the minimum required pressure to start a reactor coolant pump and the operating margin to prevent lifting of the PORVs due to normal operating pressure surges.
The licensee's current LTOP analysis, which removes the non-conservatism in a previous analysis by l
, assuming one reactor coolant pump in operation, results in a calculated pressure that exceeds the Appendix G safety margins for Salem 1 and falls just within the Appendix G safety margins for Salem 2.
The licensee has requested the use of Code Case N-514, which allows exceedance of the Appendix G safety limits by 10%. Designated Code Case N-514, the proposed alternate methodology, is consistent with guidelines developed by the American Society of Mechanical Engineers (ASME) Working Group on Operating Plant Criteria to define pressure limits during LTOP events that avoid certain unnecessary operational restrictions, provide adequate margins against failure of the reactor pressure vessel, and reduce the potential for unnecessary activation of pressure-relieving devices used for LTOP.
Code Case N-514, " Low Temperature Overpressure Protection," has been approved by the ASME Code Committee.
The content of this code case has been incorporated into Appendix G of Section XI of the ASME Code and published in the 1993 Addenda to Section XI.
In order to utilize Code Case N-514 and exceed the Appendix G safety limits, the licensee has requested an exemption to 10 CFR 50.60 in a letter dated December 22, 1994.
As a result of a teleconference between the licensee and the NRC on December 16, 1994, the licensee summarized in its letter of the same date the administrative controls currently in place for Salem, Units 1 and 2 to prevent the P/T limits from being exceeded due to injection of an Intermediate Head Safety Injection pump.
These controls will be removed after the receipt of i
this approval.
III.
Pursuant to 10 CFR 50.12, the Commission may, upon application by any interested person or upon its own initiative, grant exemptions from the
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requirements of 10 CFR Part 50 when (1) the exemptions are authorized by law, will not present an undue risk to public health or safety, and are consistent F
with the common defense and security; and (2) when special circumstances are present.
Special circumstances are present whenever, according to 10 CFR 50.12(a)(2)(ii), " Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule...".
The underlying purpose of 10 CFR 50.60, Appendix G, is to establish fracture toughness requirements for ferritic materials of pressure-retaining components of the reactor coolant pressure boundary to provide adequate margins of safety during any condition of normal operation, including anticipated operational occurrences, to which the pressure boundary may be subjected over its service lifetime.Section IV.A.2 of this appendix requires that the reactor vessel be operated with P/T limits at least as conservative as those obtained by following the methods of analysis and the required i
margins of safety of Appendix G of the ASME Code.
Appendix G of the ASME Code requires that the P/T limits be calculated:
(a) using a safety factor of 2 on the principal membrane (pressure) stresses, (b) assuming a flaw at the surface with a depth of one-quarter (1/4) of the vessel wall thickness and a length of six (6) times its depth, and (c) using a conservative fracture toughness curve that is based on the lower bound of l
static, dynamic, and crack arrest fracture toughness tests on material similar to the Salem reactor vessel material, l
e
. In determining the setpoint for LTOP events, the licensee proposed to use safety margins based on an alternate methodology consistent with the proposed ASME Code Case N-514 guidelines. The ASME Code Case N-514 allows determination of the setpoint for LTOP events such that the maximum pressure in the vessel would not exceed 110% of the P/T limits of the existing ASME Appendix G.
This results in a safety factor of 1.8 on the principal membrane stresses. All other factors, including assumed flaw size and fracture toughness, remain the same. Although this methodology would reduce the safety factor on the principal membrane stresses, the proposed criteria will provide adequate margins of safety to the reactor vessel during LTOP transients and i
will satisfy the underlying purpose of 10 CFR 50.60 for fracture toughness requirements.
IV.
For the foregoing reasons, the NRC staff has concluded that the licensee's proposed use of the alternate methodology in determining the acceptable setpoint for LTOP events will not present an undue risk to public health and safety and is consistent with the common defense and security. The NRC staff has determined that there are sper.ial circumstances present, as specified in 10 CFR 50.12(a)(2), such that application of 10 CFR 50.60 is not necessary in order to achieve the underlying purpose of this regulation.
Accordingly, the Commission has determined that, pursuant to 10 CFR l
50.12(a), an exemption is authorized by law, will not endanger life or i
property or common defense and security, and is, otherwise, in the public interest.
Therefore, the Commission hereby grants an exemption from the requirements of 10 CFR 50.60 such that in determining the setpoint for LTOP
4 t events, the Appendix G curves for P/T limits are not exceeded by more than 10 percent in order to be in compliance with these regulations. This exemption is applicable only to LTOP conditions during normal operation.
Pursuant to 10 CFR 51.32, tha Commission has determined that the granting of this exemption will not have a significant effect on the quality of the human environment (60 FR 7804).
This exemption is effective upon issuance.
FOR THE NUCLEAR REGULATORY COMMISSION I
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L v
Va a,
e or Division of Reacto rojects - I/II Office of Nuclear R actor Regulation Dated at Rockville, Maryland, this 13th day of February 1995
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