ML20087M702

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Responds to NRC Re Violations Noted in IE Insp Repts 50-272/83-27 & 50-311/83-30.Corrective Actions: Emergency Instruction Revised to Increase Limits for Vibration & Decision Made to Remove Action Requirements
ML20087M702
Person / Time
Site: Salem  PSEG icon.png
Issue date: 11/28/1983
From: Liden E
Public Service Enterprise Group
To: Starostecki R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20087M688 List:
References
NUDOCS 8403300183
Download: ML20087M702 (3)


Text

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' OPSEG

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Public Service Electric and Gas Company P.O. Box 236 Hancocks Bndge, New Jersey 08038 Nuclear Department November 28, 1483 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:

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 The subject inspection conducted on September 7 to October 4, 1983 identified a violation related to failure to implement proper procedures.

PSE&G's response to the violation is provided below.

ITEM OF VIOLATION 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:

Emergency Instruction I-4.20, Failure of a Reactor Coolant Pump (RCP), was not implemented or maintained from September 26, 1983 to October 3, 1983, in that the unit was not shut down due to excessive RCP shaft vibration nor were the vibration limits increased to reflect higher technically justifiable emergency action limits and continued operation.

Reply to Item of Violation 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 Mh0 0

The Energy People 95P 68 (BCM! 1082.

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O' U.S.

Nuclear Regulatory Commission 11/28/83 apparent to the operators that 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 confira 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 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, 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 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.

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 membersoof Station management and also members of Nuclear Engineering.

The pump manufacturer was also contacted concerning the problem with the 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 remove all action requirements-based upon RCPLshaft vibration indications.

The; problem associated with the monitors is1still under evaluation by PSE&G and the Emergency Instruction will be revisedLif appropriate.

...U.

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U.S.

Nuclear Regulatory Commission 11/28/83 b.

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 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 i

that is to be performed.

This project has been in progress since December 15, 1982, and is presently scheduled to be completed in June of 1984.

c.

Date when full compliance will be achieved We are now in full compliance.

Sincerely, s

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. James Linville Senior Resident Inspector

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