ML18092B552

Responds to Violations Noted in Insp Rept 50-311/87-03. Corrective Actions:Injection Capability to All Four Cold Legs Restored,Directive Issued Containing IE Info Notice 87-001 for Review & Procedure Sp (0) 4.5.3.1 Changed

ML18092B552
Person / Time
Site:	Salem
Issue date:	04/30/1987
From:	Corbin McNeil Public Service Enterprise Group
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
IEIN-87-001, IEIN-87-1, NLR-N87077, NUDOCS 8705070009
Download: ML18092B552 (3)

Text

Public Service Electric and Gas Company Corbin A. McNeil!, Jr.

SeniorVice President -

Nuclear Public Service Electric and Gas Company P.O. Box236, Hancocks Bridge, NJ 08038 609 339-4800 MR 3 o 1987 NLR-N87077 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT NO. 50-311/87-03 SALEM GENRATING STATION UNIT NO. 2 DOCKET NO. 50-311 Public Service Electric and Gas Company (PSE&G) has received the Notice of Violation dated March 31, 1987 regarding the inoperability of both Emergency Core Cooling System (ECCS)

Residual Heat Removal (RHR) subsystems for approximately twenty hours.

Pursuant to the requirements of 10 CFR 2.201, our response to this Notice of Violation is provided in the attachment to this letter.

Attachment C

Mr. D. C. Fischer Licensing Project Manager Mr. T. J. Kenny Senior Resident Inspector Sincerely, Mr. w. T. Russell, Administrator Region I

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ATTACHMENT PUBLIC SERVICE ELECTRIC AND GAS COMPANY SALEM GENERATING STATION UNIT NO. 2 RESPONSE TO NOTICE OF VIOLATION Technical Specification Limiting Condition for Operation (LCO) 3.5.2 requires that while the reactor is in power operation, startup, or hot standby., two independent Emergency Core Cooling System (ECCS) subsystems shall be operable with each subsystem comprised, in part, of an operable Residual Heat Removal (RHR) pump and an operable flow path for low pressure safety injection.

The Final Safety Analysis Report Chapter 15 Accident Analysis for the large break loss of coolant accident was based on each RHR pump being capable of delivering low pressure safety injection flow to all four Reactor Coolant System (RCS) cold legs.

Technical Specification 3.0.3 requires that, when a Technical Specification LCO is not met, action shall be taken within one hour to place the unit in a mode in which the specification does not apply by placing it in hot ~tandby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, hot shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and cold shutdown within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Contrary to this, for approximately 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> on January 12 and 13,- 1987, neither of the ECCS subsystems met the conditions of LCO 3.5.2 in that only two of the required f iow cold injection paths were operable.

The subsystems were inoperable in that the injection valve (22 SJ 49) for one RHR pump as well as the RHR loop cross-tie valve (22 RH 19) were closed.

These were closed in support of a pl~nned maintenance activity.

This condition was identified by station personnel upon reviews performed pursuant to IE Information Notice 87-01.

Technical Specification 3.0.3 was entered and the maintenance activity was terminated with the system returned to operable status.

RESPONSE

PSE&G DOES NOT DISPUTE THE VIOLATION.

T_he root cause of this violation is the fact that the Technical Specifications and the Updated Final Safety Analysis Report (UFSAR) do not clearly delineate the fact that injection into all four RCS cold legs is required to mee~ the design bases.

Furthermore, a failure on the part of Westinghouse to promptly communicate previous industry occurrences of RHR misalignments precluded a more timely identification of this condition *at Salem Station.

CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED The immediate corrective action taken by Salem Station personnel upon review of IE Information Notice 87-01, entitled "RHR Valve

• Misalignment Causes Degradation of ECCS in PWRs," was to

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commence a unit shutdown.

Injection capability to all four cold legs was restored within three and a half hours after identification by station personnel.

Tpis action brought us into full compliance with Technical Specification 3.5.2.

An Operations Department Information Directive was issued to all Licensed Operators which contained a copy of IE Information Notice 87-01 for their review.

Also included was an interpretation of Technical Specifications 3.5.2.e and 3.5.3.d.

The interpretation defined what is required for an operable flow path of the RHR system, i.e., the capability to inject into all four RCS cold legs.

In addition, the following actions were taken.

First, Surveillance Procedure SP (0) 4.5.3.l was changed to reflect the requirement that both RH 19 valves and SJ 49 valves must be opened prior to changing from cold shutdown to hot shutdown.

Second, included in the Second Ten-Year Inspection Inservice Testing Program submitted for NRC review on March 30, 1987,. is a request for relief from the ASME Section XI code requirement to perform a full stroke test of the SJ 49 and RH 19 valves on a quarterly basis.

Currently, Technical Specification 3.0.3 is entered to perform this test.

Third, the Nuclear Training Department has incorporated into Segment 4 of the Licensed Operator Requalification training, a section on the design basis assumptions for ECCS equipment.

This training will be completed by June 30, 1987.

Fourth, a Technical Specification change request is being formulated which will clearly reflect the ECCS design bases requirements in Technical Specifications 3.5.2 and 3.5.3.

Finally, UFSAR changes have been processed that explicitly identify the ECCS design bases requirements for injection capability into all four RCS cold legs.

These changes will be issued in Amendment No. 7 to the Salem Station UFSAR.

• These actions help to ensure that the ECCS design basis requirements are met and maintained, and will serve to preclude a similar occurrence.

The following actions have been taken to improve the communication process between PSE&G And Westinghouse Electric Corporation.

PSE&G has contacted Westinghouse upper level management on two separate occasions tp strongly express concern over their failure to provide prompt notification of similar problems that occtirred at the Byron and Trojan Nuclear Plants.

Westinghouse was reminded of the importance of timely operating experience feedback and.their obligation to their customers.

In

. their response, Westinghouse indicated that, while they consider this to be an isolated case, they.have taken steps to improve their customer notification process.

The PSE&GNuclear Department's Industry Operating Experience Evaluation Program assures that applicable industry experiences are evaluated for any potential impact on Salem or Hope Creek Generating Stations *. The program is dependent on industry feedback.

This program, together with the reaffirmation of Westinghouse's obligations to its customers, provides adequate assurance of the timely dissemination of industry concerns and should serve to preclude reoccurrence of this event.