ML20140D821

Provides Results of Preliminary Review of 841124 Response to IE Bulletin 84-03, Refueling Cavity Water Leak. Response Inadequately Assesses or Justifies,From Safety Viewpoint,Use of Solitary Inflatable Cavity Seal During Refueling

ML20140D821
Person / Time
Site:	Salem
Issue date:	12/12/1984
From:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Uderitz R Public Service Enterprise Group
References
IEB-84-03, IEB-84-3, NUDOCS 8412190217
Download: ML20140D821 (2)

Text

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, o DEC 121984 Docket Nos. 50-272 50-311 Public Service Electric and Gas Company ATTN: Mr. Richard A. Uderitz Vice President - Nuclear P.O. Box 236 Hancock's Bridge, New Jersey 08038 Gentlemen:

Subject:

IE Bulletin 84-03: Refueling Cavity Water Leak The purpose of this letter is to provide you with the results of our preliminary review of your submittal dated Novamber 21, 1984. Your response to the subject Bulletin does not adequately assess or justify, from a safety viewpoint, the use of a solitary inflatable reactor cavity seal during refueling operations in light of recent experiences at other facilities.

The safety evaluation enclosed with your response attempts, in a qualitative way, to demonstrate that seal failure is unlikely. The evaluation fails to evaluate postulated failure mechanisms, mitigattun, and corrective actions in a comprehensive way.

In view of your plans to begin fuel movement from the reactor vessel in Unit 2 shortly, you are strongly urged to re-evaluate your design prior to challenging the system.

Our preliminary review of your response has identified the following def t-ciencies; Qualitative assertions (lubrication, flange size, beveled edge, rubber hardness) are unsupported by analyses or tests.

The consequences of a dropped fuel assembly or heavy load on the seal are-not addressed.

In the event of seal failure, no flow limiting feature is provided nor are l there procedures in place to aid the operators in mitigating the conse-quences of seal failure. Such consequences could also include handling of spent fuel concurrent with seal failure.

Failure mechanisms such as overpressurization or loss of air pressure are not addressed.

Assuming a postulated failure of the seal, there appears to be no redundant feature capable of performing the design function. Application of the defense-in-depth philosophy to the proposed design should be discussed.

IFFICIAL RECORD COPY NORRHOLM12/12/84 - 0001.0.0 7Jh 12/12/84

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DEC 121984 Public Service Electric and Gas 2 Company The above concerns are illustrative of an incomplete assessment. In light of the potential failu es and consequences associated with fuel handling in the reactor cavity and transfer canal, more detailed consideration should be given to the design and integrity of those features whose fullure can result in the loss of reactor cavity or transfer canal water.

Your prompt attention to this matter is warranted.

Slu r10 $ D b y c{ L l Richard W. Starostecki, Director r Division of Project and Resident Programs cc:

R. L. Mitti, General Manager - Nuclear Assurance and Regulation J. M. Zupko, Jr., General Manager - Salem Operations E. A. Liden, Manager - Nuclear Licensing and Regulation

'C. P. Johnson, Manager - Quality Assurance Nuclear Operations P. M. Krishna, Manager - Nuclear Review Board

n. J. Wetterhahn, Esquire R. Fryling, Jr. , Esquire Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of New Jersey bec:

Region I Docket Room (with concurrences)

DPRP Section Chief R. C. DeYoung, Director, IE H. Bailey, IE L. Bettenhausen, DETP RhRP 'OP ^ D r Limhoth/jm Starc st< >cki Ch,"PB,#2 4 No&rrholm At 0FFICIAL RECORD COPY t% g NORRHOLM1b/12/84-0002.0.0 12/12/84