ML18096A242

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LER 91-021-01:on 910522 & 0603,Tech Spec 3/4.8.3.1 Noncompliance Discovered.Caused by Personnel Error.Amend Implementation Event Reviewed W/Prior Tech Spec Administrator.W/910906 Ltr
ML18096A242
Person / Time
Site: Salem PSEG icon.png
Issue date: 09/06/1991
From: Pollack M, Vondra C
Public Service Enterprise Group
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-91-021, LER-91-21, NUDOCS 9109100337
Download: ML18096A242 (8)
v • d • e


Text

  • Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038 Salem Generating Station September 6, 1991 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

Dear Sir:

SALEM GENERATING STATION LICENSE NO. DPR-70 DOCKET NO. 50-272 UNIT NO. 1 SUPPLEMENTAL LICENSEE EVENT REPORT 91-021-01 This Supplemental Licensee Event Report is being submitted pursuant to 10CFR50.73. This supplement addresses an additional finding as a result of corrective action implementation. Also, corrective action status has been updated as applicable.

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f'/ C. A~a General Manager -

Salem Operations MJP:pc Distribution 9109100337 910906 PDR ADOCK 05000272 S PDR The Energy People 95-2189 (10M) 12-89 1000.qh

NRC FORM 366 16-89)

U.S. NUCLEAR REGULATORY COMMISSION A APPROVED OMB NO. 3150-0104

.* - EXPIRES: 4/30/92 ESTIMATED BURDEN PER RESPONSE TO COMPLY WTH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS. FORWARD LICENSEE EVENT REPORT (LER) COMMENTS REGARDING BURDEN ESTIMATE TO THE RECORDS AND REPORTS MANAGEMENT BRANCH (P-530), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555, AND TO THE PAPERWORK REDUCTION* PROJECT (3150-0104), OFFICE OF MANAGEMENT AND BUDGET, WASHINGTON, DC 20503.

FACILITY NAME (1) DOCKET NUMBER (21 I PAGE 131 Salem TITLE (4)

Gener~ting Station - Unit 1 I0 I 5 I 0 I 0 I 0 12 17 I 2 I 1 OF 0 17 Tech. Spec. 3/4.8.3.1 Noncompliance; Inadquate Amendment Implementation & Surv. Not Done EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (Bl

~~t~f ~ft\

MONTH YEAR SEQUENTIAL REVISION FACILITY NAMES DOCKET NUMBER(SI DAY YEAR NUMBER NUMBER MONTH DAY YEAR 0 I 5 Io Io I o I I I ols 21 2 g 1 9 11

- q 211 - 0!1 ols ol 6 9 11 0 1510 IO I o I I I OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE RcCUIREMENTS OF 10 CFR §: (Check one or more of the following) (11)

MODE (9) 1 20.402(b) 20,405(c)

,_ 50.73(o)(2)(iv) 73.71(b)

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POWER L~~~L 1 I 0 I 0 ,.._

20.405(0)(1 )(I) 20.405(oll1 Hill --x 50.3B(c)(1) 50.38(c)(2) -~

50.73(o)(2)(v) 50.73(o)(2)(vlil 73.71 (cl OTHER (Specify in Abstrect btJlow and in TtJxt, NRC Form lllllllllllll=

20.406(a)(1 )(Ill) 50.73(0)(2)(1) 50.73(o)(2)(vlll)(A) 366A) 20.405(0)(1 )(Iv) 20,406(0)(1 )(v) - 60,73(0)(2)(11) 50.73(0)(2)(111)

LICENSEE CONTACT FOR THIS LER (121

- 50,73(o)(2)(vlll)(B) 50.73(o)(2)(xl NAME TELEPHONE NUMBER AREA CODE M. J. Pollack - LER Coordinator 6 I 0 19 3 I 3 I 9 I - I 21 0 I 2 12 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

CAUSE SYSTEM COMPONENT MANUFAC-TURER R ~~o~;~~~E :.*::i:i::i:::i::::::::::::::::1:,.*1::.1::.:ii:'.:i: CAUSE SYSTEM COMPONENT MANUFAC-TUR ER I I I I I I I I I I I I I I I I I I I I I I I I I I I I SUPPLEMENTAL REPORT EXPECTED (141 MONTH DAY YEAR EXPECTED n

SUBMISSION DATE (151 YES (If yes, compl*te EXPECTED SUBMISSION DATE)

I I I ABSTRACT (Limit to 1400 soac*s, i.*.. epproxim*tely fift*en singl*-soec* typewritten lin*sl (18)

This LER supplement addresses an additional Containment.penetration overcurrent protection device Tech. Spec. 3/4.8.3.1 noncompliance (lGPXA) discovered on 8/6/91. The original LER addressed 3 Tech. Spec.

3/4.8.3.1 noncompliance events. In all events, Surv. 4.8.3.1 was not fully satisfied. The first event (discovered on 5/22/91) identified a Containment penetration overcurrent protection device which was not included in the UFSAR listing. The second event involved a determination that this device had not been surveilled as per the Surv.

requirements nor had the associated Action Statements been applied on 5/22/91. The third event (discovered on 6/3/91) identified that Tech.

Spec. Amendment 105 implementation, in April 1991 (i.e., completion of the ninth refueling outage) was inadequate. The Surv. requirements were not met for all applicable devices. The first event root cause is an incorrect schematic (which was corrected) and the second and third events are due to personnel error (i.e., a combination of poor work practices and inadequate communications). The cause of the lGPXA noncompliance is due to the inadequate implementation of Amendment 105 (i.e., related to third event). These events were reviewed with the individuals involved. As previously committed to by Unit 1 LER 272/91-019-00, INPO Good Practice OE-906 is being presented to station personnel. The U-1 UFSAR breaker list is being reviewed. A Personnel Performance Enhancement Panel meeting was held with station management and personnel directly involved in the event.

NRC Farm 366 (6-89)

I I LICENSEE EVENT REPORT (LER) TEXT CONTINUATION Salem Generating Station DOCKET NUMBER LER NUMBER PAGE Unit 1 5000272 91-021-01 2 of 7 PLANT AND SYSTEM IDENTIFICATION:

Westinghouse - Pressurized Water Reactor Energy Industry Identification System (EIIS) codes are identified in the text as {xxf IDENTIFICATION OF OCCURRENCE:

Technical Specification 3/4.8.3.1 Noncompliance; inadequate Amendment implementation and surveillance not performed Event Date/Discovery Date: Component discovered to not be included 4-26-91/5-22-91 in Specification 3/4.8.3.1 listing Event Date/Discovery Date: Amendment Implementation Inadequate 4-26-91/6-3-91 This includes the 8/6/91 concern which is addressed by this LER Supplement Event Date/Discovery Date: Surveillance Not Performed 5-22-91/6-12-91 Report Date: 9/06/91 This report was initiated by Incident Report Nos.91-348, 91-402,91-421 and 91-541.

CONDITIONS PRIOR TO OCCURRENCE:

Mode 1 Reactor Power 100% - Unit Load 1130 MWe DESCRIPTION OF OCCURRENCE:

This LER addresses three (3) Technical Specification 3/4.8.3.1 noncompliance events. In these events, Technical Specification Surveillance 4.8.3.1 requirements were not completed satisfied.

Technical Specification 3.8.3.1 (for either Salem Unit) states:

"All containment penetration conductor overcurrent protective devices required to provide thermal protection of penetrations shall be OPERABLE."

On May 10, 1991, it was identified that the Salem Unit 1 and Salem Unit 2 Updated Final Safety Analysis Report (UFSAR) lists of Containment penetration overcurrent protection devices were not consistent with each other. Specifically, the Unit 2 list identified three (3) Containment Fan Coil Unit (CFCU) Motor Space Heater molded case circuit breakers (supporting the 5 CFCUs) whereas the Unit 1 list identified only two (2) of these breakers. On May 22, 1991, it was confirmed that the Il118-5G7 breaker (for No. 12 CFCU) did have a load (it was not a spare) and should be included in the UFSAR list.

On June 12, 1991, contrary to the requirements of Technical Specifications, it was discovered that Technical Specification

LICENSEE EVENT REPORT (LER) TEXT CONTINUATION Salem Generating Station DOCKET NUMBER LER NUMBER PAGE Unit 1 5000272 91-021-01 3 of 7 DESCRIPTION OF OCCURRENCE: (cont'd) 3.8.3.1 Action requirements were not implemented nor were the required surveillances completed for the I1118-5G7 breaker when it was confirmed to not be a spare.

Technical Specification 3.8.3.1 Actions state:

"a. Restore the protective device(s) to OPERABLE status or de-energize the circuit(s) by tripping either the primary or backup protective device, or racking out or removing the primary or backup device within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, declare the affected system or component inoperable, and verify the primary or backup protective device to be tripped, or the primary or backup device racked out or removed at least once per 7 days thereafter; the provisions of Specification 3.0.4 are not applicable to overcurrent devices in circuits which have their primary or backup protective device tripped, or which have the primary or backup device racked out or removed, or

b. Be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Cold Shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />."

The other Technical Specification 3/4.8.3.l noncompliance event was dis.covered on June 3, 1991, when it was identified that implementation of Technical Specification Amendment 105 in April 1991 (i.e., completion of the recent ninth refueling outage) was inadequate.

Discovery of this Unit 1 event occurred as a result of *a surveillance compliance concern (identified by Station Quality Assurance) with Salem Unit 2 Technical Specification 4.8.3.1.b. The Unit 2 concern proved invalid as a result of a review of historical records in which preventive maintenance work, which satisfied the Surveillance requirements, was found.

Salem Unit 1 Technical Specification 3/4.8.3.1 was added via Amendment 105. Amendment implementation requirements included verification that all necessary Unit 1 containment penetration conductor overcurrent protective devices were operable. The molded case circuit breakers were to be verified as having met Technical Specification Surveillance 4.8.3.1.b; however, this was not done.

A detailed review was subsequently conducted to determine which Unit 1 molded case circuit breakers did not have documented completed preventive maintenance performed within the past five (5) years. Of the 134 breakers involved, seven (7) were identified as not meeting Technical Specification Surveillance 4.8.3.1.b requirements.

Technical Specification Action Statement 3.8.3.1.a was then entered on June 3, 1991 at 1735 hours0.0201 days <br />0.482 hours <br />0.00287 weeks <br />6.601675e-4 months <br />.

Technical Specification 4.8.3.1 (for either Salem Unit) states:

.. II LICENSEE EVENT REPORT (LER) TEXT CONTINUATION Salem Generating Station DOCKET NUMBER LER NUMBER PAGE Unit 1 5000272 91-021-01 4 of 7 DESCRIPTION OF OCCURRENCE: (cont'd)

"All required containment penetration conductor overcurrent protective devices shall be demonstrated OPERABLE:

Technical Specification 4.8.3.1.b states:

At least once per 60 months by subjecting each circuit breaker to an inspection and preventive maintenance in accordance with procedures prepared in conjunction with its manufacturer's recommendations."

As part of the Corrective Action to the above events, a detailed review of the Salem Unit 1 UFSAR breaker list was conducted. The records needed to ensure compliance with Technical Specification 4.8.3.1.b were reviewed. On August 6, 1991, Unit 1 breaker lGPXA "Pressurizer Heater Backup Breaker" was determined to have an inadequately completed Surveillance. The completed procedure, for which credit had been taken, was not adequate. No other additional discrepancies were identified. Technical Specification 3.8.3.1 Action b was entered upon this discovery on August 6, 1991 at 0930 hours0.0108 days <br />0.258 hours <br />0.00154 weeks <br />3.53865e-4 months <br />.

APPARENT CAUSE OF OCCURRENCE:

Investigation of why the Unit 1 UFSAR Table did not include the Illl8-5G7 breaker revealed that the "one line schematic" was incorrect. The one line schematics were used, by Engineering, in the generation of the Unit 1 UFSAR Table of containment penetration conductor overcurrent protective devices. A review of the detailed electrical schematic print showed the correct circuit c~nfiguration.

The root cause of not completing the surveillance for the I1118-5G7 breaker on May 22, 1991 is personnel error. The Technical Specification Administrator did not ensure that Surveillance requirements were met due to poor work practices. He did not review work orders nor question on-going investigations in order to confirm assumed work activity completions. These activities included performance of the Surveillance.

A contributing factor to not having completed the Illl8-5G7 breaker surveillance was inadequate communications between Maintenance, System Engineering and the Technical Specification Administrator. As each group (Maintenance and System Engineering) reached the understanding of the breaker being a Containment penetration overcurrent protection device on May 22, 1991, this information was not forwarded to the Technical Specification Administrator or Operations to ensure Surveillance and Action Statement requirements were met.

The root cause of not correctly implementing Unit 1 Technical Specification Amendment 105 is personnel error. Inadequate communications between the Technical Specification Administrator and the Station-Planning Department had occurred.

~~~~~~lr--~~~~----t LICENSEE EVENT REPORT (LER) TEXT CONTINUATION j

Salem Generating Station DOCKET NUMBER LER NUMBER PAGE Unit 1 5000272 91-021-01 5 of 7 APPARENT CAUSE OF OCCURRENCE: (cont'd)

The Technical Specification Administrator did not ensure that a "Surveillance Task Request" form (Administrative Procedure

.NC.NA-AP.ZZ-0010, "Preventive Maintenance") was initiated for each subject molded case circuit breaker. This led to miscommunication (verbal) with Planning Department personnel who understood that to meet Technical Specification Surveillance 4.8.3.1.b for Amendment 105 implementation, the subject molded case circuit breakers were to be surveilled over the next five (5) years (in conjunction with Surveillance 4.8.3.1.a2). Consequently, verification of having adequate preventive maintenance within the past five (5) years (Surveillance 4.8.3.1.b) of the 134 molded case circuit breakers was not assured upon restart of Unit 1 after completion of the ninth refueling outage.

In support of Amendment 105 implementation, the Technical Specification Administrator initiated ATS Open Items (a computerized commitment tracking system) including one to the Outage Manager to ensure recurring tasks were scheduled and completed prior to startup from the ninth refueling outage. The Outage Manager's response indicated that the Surveillance requirements (for Amendment implementation) were appropriately met in accordance with written documentation. However, this was not correct. This was apparently due to miscommunications between the Technical Specification Administrator and the Outage Manager.

ANALYSIS OF OCCURRENCE:

The containment penetration conductor overcurrent protective devices (i.e., breakers) ensure against the overheating of electrical wiring entering containment. The surveillance requirements ensure continued reliable operation of this equipment.

As identified in the Description Of Occurrence Section, in addition to the I1118-5G7 breaker, seven (7) of the 134 Unit 1 molded case circuit breakers did not meet Surveillance 4.8.3.1.b requirements.

Surveillance of the I1118-5G7 breaker was completed on June 13, 1991, at which time the Action Statement for this breaker was exited. The Surveillance, of the seven (7) additional breakers was successfully completed (and the Action Statement exited) on June 6, 1991.

The seven (7) Unit 1 molded case circuit breakers involved are:

I1118-6GY No. 1 Reactor Sump Pump Motor I1118-4DX No. 16 In-Core Flux Detector Positioning Motor I1118-1DX No. 14 In-Core Flux Detector Positioning Motor I1118-6JY No. 12 Containment Sump Pump Motor I1118-4AX No. 12 Reactor Coolant Pump Motor Heater I1118-1AX No. 12 Iodine Removal Unit Motor I1118-1EX No. 15 In-Core Flux Detector Positioning Motor The Surveillance for the lGPXA, "Pressurizer Heater Backup Breaker",

was completed on August 7, 1991, at 0552 hours0.00639 days <br />0.153 hours <br />9.126984e-4 weeks <br />2.10036e-4 months <br />, at which time the

LICENSEE EVENT REPORT (LER) TEXT. CONTINUATION Salem Generating Station DOCKET NUMBER LER NUMBER PAGE Unit 1 5000272 91-021-01 6 of 7 ANALYSIS OF OCCURRENCE: (cont'd)

Action Statement was exited.

None of the above subject breakers failed its subsequent surveillance. Therefore, this event did not affect the health or safety of the public.

Since the Salem Unit 1 Amendment implementation requirements were not fully met and the Technical Specification 3.8.3.1 Action requirements (for not completing the Illl8-5G7 breaker surveillance) were not implemented, this event is reportable to the Nuclear Regulatory Commission in accordance with Code of Federal Regulations 10CFR

50. 7 3 (a) ( 2) ( i) ( B) .

CORRECTIVE ACTION:

The inadequate Amendment implementation event has been reviewed with the prior Technical Specification Administrator, who had coordinated the Technical Specification Amendment No. 105 implementation.

The current Technical Specification Administrator (involved in the Ill18-5G7 surveillance noncompliance) has been counseled. The need to ensure that a positive overview of work activities involving Surveillance compliance was stressed.

As previously committed to by Unit 1 LER 272/91-019-00 (dated May 30, 1991), the importance of attention to detail, procedure compliance, good work practices and good communications will be reviewed with applicable station personnel at working level meetings. This will be accomplished by using the eleven (11) lessons contained in INPO Good Practice OE-906, "Increasing Personnel Awareness of Frequent Causes of Human Performance Problems".

Administrative Procedure AP-12 ("Technical Specification Surveillance Program") was revised on March 8, 1991 to add administrative controls including an "Amendment Review Form", used to identify those documents requiring revision to support Amendment implementation.

Subsequent to the events discussed in this LER, a detailed review of the Salem Unit 1 UFSAR breaker list was conducted. The records needed to ensure compliance with Technical Specification 4.8.3.1.b were reviewed in detail to ensure their adequacy for use in Surveillance compliance and Amendment 105 implementation. As discussed in the Description of Occurrence section, only one breaker (lGPXA) was determined to not have an adequately completed surveillance. The surveillance was subsequently performed successfully.

As a result of finding the lGPXA breaker surveillance inadequacy, a detailed review has been initiated to ensure full compliance with Technical Specification Surveillance 4.8.3.1.a.2 for the Unit 1 breakers.

.. I LICENSEE EVENT REPORT (LER) TEXT CONTINUATION Salem Generating Station DOCKET NUMBER LER NUMBER PAGE Unit 1 5000272 91-021-01 7 of 7 CORRECTIVE ACTION: (cont'd)

The Unit 1 and Unit 2 CFCU space heater breaker circuit design has been verified. The electrical one-line diagram for the Unit 1 circuit has been corrected to clearly identify that the 5G5 and 5G7 breakers apply to different CFCU space heaters and are not redundant to each other.

A Personnel Performance Enhancement Panel (PPEP) meeting was conducted, with station management and personnel directly involved in the event, to review the causal factors addressed by this LER.

Additional corrective actions to be completed include:

1. The roles and responsibilities of the Technical Specification Administrator will be assessed and clearly defined.
2. AP-12 will be reviewed to ensure that the responsibility for initiating Recurring Task Request Forms for Technical Specification Amendment implementation is better defined.
3. The process for detailed review of Technical Specification Amendments, prior to implementation, will be assessed to determine if a higher level of review is warranted.
4. Technical Specification Administrator qualifications and training will be reviewed and enhanced as applicable.

General Manager -

Salem Operations MJP:pc SORC Mtg.91-092

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