ML18082B016

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Advises That,Due to Internal Communications problems,800328 Ltr Responding to TMI-2 Lessons Learned Section 2.1.3a, Erroneously Advised That Limit Switches on Power Operated Relief Valves Were Seismically & Environmentally Qualified
ML18082B016
Person / Time
Site: Salem 
Issue date: 08/28/1980
From: Mittl R
Public Service Enterprise Group
To: Schwencer A
Office of Nuclear Reactor Regulation
References
NUDOCS 8009040352
Download: ML18082B016 (2)


Text

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Public Service Electric and Gas Company 80 Park Place Newark, N.J. 07101 Phone 201 /622-7000 Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.

20555 August 28, 1980

.ATTENTION:

Mr. A. Schwencer, Acting Chief Licensing Branch 3 Division of Licensing Gentlemen:

PORV LIMIT SWITCH QUALIFICATION NO. 2 UNIT SALEM NUCLEAR GENERATING STATION DOCKET NO. 50-311 In our letter to the Qirector of Nuclear Reactor Regulation dated March 28, 1980, responding to requirements related to 11TMI-2 Lessons Learned 11

, under Section 2.1.3a, we stated that the limit switches on our power operated relief valves (PORV) were seismically and environmentally qualified.

NRC was notified verbally on August 22, 1980, that contrary to the above the installed limit switches had not been qualified. The error in our March 28, 1980 letter was due to an internal communication problem and was discovered during our review of equipment qualification records.

A history of events relating to the limit switches follows:

1. The NRC letter of October 30, 1979 on the subject "Discussion of Lessons Learned Short Term Requirements" was reviewed.

An internal memorandum dated November 15, 1979, was prepared which indicated that our existing limit switches for the PORV valves complied with the requirements of Section 2.1.3a, Par. 3 of the above NRC letter.

2. Subsequently, after further consideration of the requirements as clarified in the above letter, an internal memorandum dated December 14, 1979 indicates that we decided to go ahead and replace the switches with readily available seismically and environmentally qualified limit switches. These switches were ordered on December 20, 1979 and delivered to the site on December 27, 1979.
3. In our letter to the Director of Nuclear Reactor Regulation dated January 4, 1980, Docket No. 50-311 concerning "Request for Additional Information Resulting From the Three Mile Island 2 Accident 11 we stated that the limit switches would be replaced by seismically and environ-mentally qualified switches as soon as possible.

The Energy People. 'LC'""

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Dir. of Nuc. Reactor Reg. 8/28/80

4.

On March 24, 1980, an Engineering Change Notice (ECN) number was assigned which would be used to replace the existing limit switches with the new limit switches. At that time (unit under construction) an ECN was required to make any changes in the approved design. A completed ECN includes the details required to do the work designated.

5. It was at this time, when assembling information for our March 28, 1980 letter, that an error in interpretation was made in the verbal exchange of information, resulting in the inaccurate statement that the switches*were seismically and environmentally qualified.
6. Subsequently when the unit passed from the construction *phase to the operating phase, ECN's on which work had not been completed were re-quired to be changed to Design Change Requests (OCR).

The information on the limit switch change was forwarded to the Engineering Department on documents dated April 30, 1980. Unfortunately the documents did not indicate that part of the work contained therein pertained to an NRC commitment and it was not assigned a high priority.

7.

In assembling the data necessary to determine the environmental quali-fication of equipment our reviewer questioned the type of limit switches.being used. This information had been obtained from drawings.

The reviewer was aware that a commitment had been made to change the limit switches.

8.

An investigation was immediately made to determine the type of limit switch actually installed. A visual check at the site confirmed that the new limit switches had not been installed. The NRC was promptly informed.

9.

The OCR necessary to change the limit switches was immediately issued.

Instructions are being issued that all "Design Change Requests" must include reference to any commitment dates given to the Nuclear Regulatory Commission.

Should you have any questions, do not hesitate to contact us.

FAC:gmv CC Mr. L. Morrholm Salem Resident Inspector r_;;;;--

R. L. Mittl General Manager -

Licensing and Environment Engineering and Construction