ML20087M695
| ML20087M695 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 03/06/1984 |
| From: | Liden E Public Service Enterprise Group |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20087M688 | List: |
| References | |
| NUDOCS 8403300177 | |
| Download: ML20087M695 (4) | |
Text
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O PSEG Public Service Electnc and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038 Nuclear Depadment March 6, 1984 U.
S.
Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406 Attention:
Mr. Richard W.
Starostecki, Director Division of Project and Resident Programs Gentlemen:
SUPPLEMENTAL RESPONSE NRC COMBINED INSPECTION 50-272/83-27 AND 50-311/83-30 SALEM GENERATING STATION NO. 1 AND 2 UNITS DOCKET NOS. 50-272 AND 50-311 During the subject inspection conducted on September 7 through October 4, 1983, a violation was identified related to failure to follow an Emergency Instruction.
Public Service Electric and Gas Company (PSE&G) responded to this violation by letter dated November 23, 1983.
As a result of subsequent discussions with the Salem Senior Resident Inspector, we are hereby submitting supplemental information.
Changes to the November 28, 1983 responce are noted by a vertical line on the right-hand margin.
ITEM OF V1OLATION Technical Specification 6.8.1 requires that written procedures shall be established, implemented, and maintained covering applicable procedures recommended in Appendix "A"
of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Appendix A requires procedures for combating emergencies and other significant events such as loss of core coolant flow.
Contrary to the above:
N Emergency Instruction I-4.20, Failure of a Reactor
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Coolant Pump (RCP), was not implemented or maintained from September 26, 1983 to October 3, 1983, in that.
T the unit was not shut down due to excessive RCP sh&ft 190 vibration nor were the vibration limits increased to pg reflect higher technically justifiable emergency gg action limits and continued operation.
oo Q4 Reply to Item of Violation 25 6te When the number 21 Reactor Coolant Pump (RCP) reached ' the alarm -
condition, -the actions - required by Emergency Instruction I.4.20, Failure of a Reactor Coolant Pump, were not taken since it was The Energy Peopkr 95 2568480 % 11 82
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Nuclear-Regulatory Commission 3/06/84 apparent to the operators titat no other RCP parameters supported the indication of the shaft monitor.
Where redundant indica-tions exist or where there are other parameters that can be monitored to confirm that a problem exists, our operators are instructed to confirm that the redundant indications or support-ing parameter indications reflect that the problem is real and requires immediate corrective action.
Problems had been en-countered in the past with the reactor coolant pump vibration shaft monitors, and these have been identified by PSE&G for i
resolution.
It was common knowledge to our operators that the RCP shaft vibration monitors were not the most accurate indica-tions of RCP vibration.
However, even with their associated problems, the monitors were still useful for indication of a potential or developing RCP malfunction and therefore were not declared inoperable.
When the indication for 21 RCP shaft vibration monitor. reached the alarm setpoint,1 the operators confirmed that other supporting instrumentation on 21 RCP did not reflect any problem.
Included in the supporting instrumen-tation was the RCP motor flange vibration monitors which were i
considered to provide an accurate indication of. pump vibration.
Based upon the indications of supporting instrumentation and the fact that the shaft vibration monitors were known to have prob-lems associated with them, a decision was made not to comply with the action requirements of the Emergency' Instruction and not to. shut down the unit-based upon the single.non-supported indication.
Due to an oversight, PSE&G failed to change.the action requirements of the Emergency Instruction to relect.
current operating conditions and policy.
PSE&G recognizes that deviating from established Emergency Instructions is contrary to prudent management philosophies'and-will not be practiced or condoned unless a specific ~ emergency condition exists warranting such deviation and is properly documented.
In-this isolated case, a review of theEproblems-associated with the RCP vibration monitors was in progress along with an evaluation of the information -provided by redundant instrumentation.
It is recognized that revised _ instructions should have been initiated in the Emergency Instructions prior-to the event which ultimately warranted a deviation from the previously established instructions, _.our corrective steps which will be taken sto avoid further violations addresses this? point.
We shall continue; to foster and. enforce' strict compliancef to established Emergency _ Instructions.
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Nuclear Regulatory Commission 3/06/84-a.
Corrective steps which have been taken and results achieved The Operating Engineer discussed the problem associated with the RCP shaft vibration monitors with other members of Station management and also members of Nuclear Engineering.
The pump manufacturer was also contacted concerning the.
problem with.he shaft vibration monitors.
Based upon these discussions, an initial decision was made to increase the limits for vibration in the Emergency Instruction and this was done with an on-the-spot-change to the procedure.
Subsequently, due-to additional evaluation of the problem with the monitors and based upon engineering and the manu-facturer's recommendations, the requirements.to take any action based on the shaft vibrations monitors was deemed inappropriate.
The Emergency Instruction was revised to j
remove all action requirements based upon RCP shaft vibration indications.
j The problem associated with the monitors is still under evaluation by PSE&G and the Emergency Instruction will be revised if appropriate.
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Corrective steps which will be taken to avoid further violations To prevent similar events.from occurring if operating conditions or policies change, the appropriate Emergency Instruction action requirements will be : revised to-reflect-the new conditions and policy changes.
Additionally, as part of the Emergency Operating Procedure / Abnormal-Operating 1 Procedure project required the NUREG-0737, all current Emergency Instructions are being reviewed for possible.
problem areas such as the one. that was ' identified in EI-I-4.20.
Where conditions require an evaluation prior to taking action, the procedures will reflect the, evaluation that is to be performed.
'This project has been 'in; progress since December 15, 1982, and is presently' scheduled to Jbe completed in June of 1984.
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Nuclear Regulatory Commission 3/06/84 c.
Date when full compliance will be achieved We are now in full compliance.
Sincerely, E.
A.
Liden Manager - Nuclear Licensing and Regulation cc:
Director, Office of Inspection and Enforcement Nuclear Regulatory Commission Washington, D.C.
20555 Mr. Donald C.
Fischer Licensing Project Manager Mr. Janes Linville Senior Resident Inspector