ML18094B291
| ML18094B291 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 01/31/1990 |
| From: | LABRUNA S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLR-N90025, NUDOCS 9002140264 | |
| Download: ML18094B291 (5) | |
See also: IR 05000272/1989013
Text
- Public Service Electric and Gas Company * Stanley LaBruna Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4800
Vice President
-Nuclear Operations
- JAN 3 1 1990 NLR-N90025
U.S. Nuclear Regulatory
Commission
Document Control Desk Washington
DC 20555 Gentlemen;
SUPPLEMENTAL
RESPONSE;
NOTICE OF DEVIATION
272/89-13-04
SALEM GENERATING
STATION UNIT NO. 1 DOCKET NO. 50-272 Public Service Electric and Gas hereby transmits, as Attachment
1 to this letter, a description
of the planned modifications/actions
to achieve compliance
with Regulatory
Guide 1.97. This information
supplements
our previous submittals
transmitted
September
5, 1989 and December 28, 1989. If there are any questions
regarding
the attached information, please feel free to contact us. Sincerely, Attachment
- * Document Control Desk NLR-N90025
c Mr. J. c. Stone Licensing
Project Manager Mr. T. Johnson Senior Resident Inspector
2 Mr. w. T. Russell, Administrator
Region I Mr. Kent Tosch, Chief * New Jersey Department
of Environmental
Protection
Division of Environmental
Quality Bureau of Nuclear Engineering
CN 415 Trenton, NJ 08625 JAN 3 1 l990
- * ATTACHMENT
TO NLR-N90025
SUMMARY OF MODIFICATIONS
REQUIRED TO PROVIDE TYPE A, CATEGORY 1 INSTRUMENTATION
FOR THE INDICATION
OF A STEAM GENERATOR
TUBE RUPTURE PSE&G has evaluated
potential
modifications
to the Channel R46A-E High Range Main Steam Line Radiation
Monitors required to assure that Regulatory
Guide (RG) 1.97 Type A, Category 1 instrumentation
is available
for the detection
and identification
- of a steam generator
tube rupture (SGTR) at Salem Generating
Station Unit Nos. 1 & 2 (SGS 1 & 2). The subject evaluation
is documented
by PSE&G Engineering
Evaluation (EE) S-C-VAR-CEE-0388, "Engineering
Evaluation
Tube Rupture Indication
Requirements
at SGS 1 & 2 11* The following
is a summary description
of the modifications
to be* accomplished
to assure compliance
with RG 1.97 requirements.
PSE&G has concluded
that the Channel R46A-E High Range Main Steam Line Monitors meet the RG 1.97 requirements
for Type A, Category 1, with the exception
that the monitors do not meet the Category 1 requirements
for redundancy.
The Channel R46E High Range Main Steam Line Monitor does not by design provide redundancy
for the Channel R46A-D High Range Main Steam Line Monitors.
Rather, the R46E detector and associated
instrumentation
serves as a backup to the R46A-D monitors and provides primary indication
of main steam line radiation
in the event of failure of any one R46A-D detector and/or associated
instrumentation.
The R46E monitor may be used to detect a SGTR and to determine
the specific faulted steam generator
based upon a comparison
of the R46E alarm state/indication
to the alarm state/indication
of the remaining
three (3) operable monitors.
PSE&G has further concluded
that, upon implementation
of the modifications
specified
below, sufficient
instrumentation
is installed
to the SGS 1 & 2 units for the indication
of a SGTR. This conclusion
is based upon; a) the instrumentation
previously
used at eight (8) other operating
nuclear units to detect actual SGTRs, b) the technical
guidance provided by the Westinghouse
Owners Group (WOG) relative to the indication
of a SGTR, and c) the functionally
redundant
instrumentation
available
at SGS 1 & 2 for the indication
of a SGTR. The following
instruments
are identified
as a functionally
redundant
set for the purpose of SGTR detection:
1
- * * * R46A-E High Range Main Steam Line Radiation
Monitors * steam Generator
Narrow Range Level Instruments
Wide Range Level Instruments
- R15 Condenser
Air Ejector Exhaust Radiation
Monitor These instruments
bear a known relationship
in their response to a SGTR as evidenced
by actual SGTR events at other nuclear units. Functional
redundancy
for the indication
of a parameter
by diverse instrumentation
has been previously
discussed, relative to AFW flow, and found acceptable
by the NRC in Safety Evaluation
Report, Supplement
No. 4, II.E, Auxiliary
Indication
(2.1.7.b-NUREG-0578), April 1980. See also Safety Evaluation, Salem Unit No. 1, Auxiliary
Automatic
Initiation
and Flow Indication, Action Plan Item II.E.1.2, June 16, 1981 and Safety Evaluation, Salem Unit No. 2, Automatic
Initiation
and Flow and Steam Generator
Level Indication
for the Auxiliary (Emergency)
System, June 22, 1981. The R15 Condenser
Air Ejector Exhaust Radiation
Monitor is not qualified
for Type A Category 1 service in accordance
with RG 1.97 due to the monitor's
location in the seismic class 3 Turbine Building.
However, due to the high reliability
demonstrated
by equivalent
instruments
during actual SGTR events, it is reasonable
to credit the R15 monitor as a functionally
redundant
indication
of a SGTR. As a measure of prudency, this indication
must be evaluated
in conjunction
with other instrumentation
of the functionally
redundant
set to assure that actions are not taken without consideration
for qualified
instruments.
All other instruments
of the functionally
redundant
set are, or will be, qualified
for Category 1 service in accordance
with RG 1.97. To provide for the qualification
and reliability
of the functionally
redundant
set of instrumentation
credited for the indication
of a SGTR, the following
modifications
will be implemented:
1) A Design Change Package (DCP) will be developed
in accordance
with PSE&G approved procedures
to change the power provided to R46A-D and associated
instruments
from vital instrument
bus (VIB) C to another VIB so that a loss of VIB C will not.result
in the loss of high range main steam line radiation
monitoring
and a loss of all steam generator
wide range level indication, also powered from VIB C. 2) A DCP will be developed
in accordance
with PSE&G approved procedures
to lower the setpoints
associated
with the R46A-E warning alarms and the R46A-E high alarms to be 2 . I
- * reasonably
consistent
with the radiation
levels experienced
during actual SGTR events at other nuclear units. 3) Design Change Packages lSC-2154 and 2SC-2154, "Salem Unit 1 (2) Control Room Modification, Phase 2 11 have been issued and will implement
the replacement
of the non Class lE Steam Generator
Narrow Range Level indicators, among others, with Class lE indicators.
This will result in the Steam Generator
Narrow Range Level instrument
loops being qualified
for Category 1 service in accordance
with the requirements
of RG 1.97. As stated in PSE&G Letter NLR-N89180, these modifications
will be accomplished
as soon as possible, however; in no case will the work be deferred beyond the tenth and sixth refueling
outages for Salem Units 1 and 2, respectively.
These outages are presently
scheduled
for the Fall of 1991 and Spring of 1992. To further assure the qualification
and reliability
of the functionally
redundant
set of instrumentation, the subject instrument
loops will be reviewed for compliance
to the SGS physical separation
and electrical
isolation
criteria developed
in accordance
with Project Scope Proposal 126-89-0677, "Evaluation
of Specific Instrument
Loops Relative to Separation/Isolation
Criteria and the Reg. Guide 1.97 Licensing
Position, July 14, 1989 11* As stated in PSE&G Letter NLR-N89180, the present schedule for this project calls for completion
of the compliance
review by November 1990. The completion
of the planned modifications, the in-progress
compliance
review, and the proposed procedural
review/revisions
will provide assurance
that the detection
of a SGTR and determination
of the ruptured steam generator
may be accomplished
in accordance
with; a) the Type A, Category 1 requirements
of RG 1.97, b) the technical
guidance provided by the Westinghouse
Owners Group, and c) via instrumentation
proven to indicate a SGTR steam generator
during actual SGTRs. 3