ML18102A309

LER 96-007-00:on 960716,containment Penetration Conductor Overcurrent Circuit Breakers Had Not Been Demonstrated Operable Per Ts.Caused by Failure to Assure That Info Was Incorporated Into Sr.Procedures reviewed.W/960814 Ltr

ML18102A309
Person / Time
Site:	Salem
Issue date:	08/14/1996
From:	Garchow D, Hassler D Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-96-007-02, LER-96-7-2, LR-N96239, NUDOCS 9608200209
Download: ML18102A309 (6)

Text

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• ops~G Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038-0236 Nuclear Business Unit AUG 14 1996 LR-N96239 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

LER 311/96-007-00 SALEM GENERATING STATION - UNIT 2 FACILITY OPERATING LICENSE NO. DPR-75 DOCKET NO. 50-311 This Licensee Event Report entitled "Missed Surveillance for Containment Penetration Overcurrent Protection Devices" is being submitted pursuant to the requirements of the Code of Federal Regulations 10CFR50. 73 (a) (2) (i) (B). David F. archow General Manager - Salem Operations Attachment SORC Mtg. 96-108 JMO/tcp C Distribution LER File 3.7

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__{ [. _;.< ,_;-* 9608200209 960814 PDR ADOCK 05000311 5 PDR 95-2168 REV. 6/94

Document Control Desk LR-N96239 Attachment A The following items represent the commitments that Public Service Electric & Gas (PSE&G) made to the Nuclear Regulatory Commission (NRC) relative to this LER (311/96-007-00). The commitments are as follows:

1. Conduct the required surveillance testing prior to Unit 2 entry into Mode 4.

2. Complete the review of Unit 1 containment penetration conductor overcurrent procedures to identify other instances of non-compliance due to missing breakers. This review will be completed by September 13, 1996.

3. Complete an evaluation of the engineering review process and interface methods used to assure the accuracy of design engineering information used by Technical Specification procedures by March 31, 1997.

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150-0104 (~*95) EXPIRES 04/30/98 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS MANDATORY INFORMATION COUECTION REQUEST: 50.0 HRS. REPORTED LESSONS LEARNED ARE INCORPORATED INTO THE LICENSING PROCESS AND FED BACK TD INDUSTllY. FORWARD COMMENTS REGARDING LICENSEE EVENT REPORT (LER) BURDEN ESTIMATE TD THE INFORMATION AND RECORDS MANAGEMENT BRANCH (T-6 F33l. U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555-0001, AND TO THE PAPERWORK REDUCTION PROJECT (3150-0104), OFFICE OF MANAGEMENT AND BUDGET, (See reverse for required number of WASHINGTON, DC 20503. digits/characters for each block) FACILITY MAME 111 DOCKET IUMBEI (21 PAGE (31 SALEM GENERATING STATION UNIT 2 05000311 1 OF 4 TITLE 141 Missed Surveillance of Containment Penetration Overc~rrent Protection Devices EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED !Bl MOITH DAY YEAR YEAR I SEQUEITIAL NUMBER I REVISIOI NUMBER MOITH DAY YEAR FACILITY IAME DOCKET IUMBER FACILITY IAME DOCKET IUMBER 07 16 96 96 007 00 08 14 96 OPERATING N THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: !Check one or morel (11) MODE(9) 20.2201(b) 20.2203(a)(2J(v) X 50.73(a)(2)(i) 50.73(e)(2)(viii) POWER 20.2203(a)(1) 20.2203(a)(J)(i) 50.73(a)(2lfiil LEVEL (10) 20.2203(a)(2)(i) 20.2203(a)(3)fii) 50.73(a)(2)(iii) 20.2203(a)(2)(ii) 20.2203(a)(4) 50.73(a)(2)fiv) 20.2203(a)(2lfiiil 50.36(c)(1) 50.73(a)(2)(v) 20.2203(a)(2)(iv) 50.36(c)(2) 50.73(a)(2)(vii) LICENSEE CONTACT FOR THIS LER (12) NAME TELEPHONE NUMBER (lncludo Ar11 CodoJ Dennis V. Hassler, LER Coordinator 609-339-1989 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13) ll--CA_U_SE---+--SY-ST_E_M_+-_C_O_MP_O_*E_IT_+-_M_A_*U_F-AC-TU-R-ER-1---1~-~-o:-;:-:s_LE--{l:l---CA-US-E-+--SY_S_TE_M_+--C-OM_P_O_*E_IT_+--MA-IU-FA_C_TU_RE_R_l--_R_~~-O._R;-::_~_E ----ll SUPPLEMENTAL REPORT EXPECTED (14) EXPECTED MONTH DAY YEAR YES (If yes, complete EXPECTED SUBMISSION DA TE). x IND SUBMISSION DATE (15) I ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) (16) On July 16, 1996, a detailed comparison of surveillance test procedures against engineering calculations identified that five containment penetration conductor overcurrent protective devices (circuit breakers) had not been demonstrated operable per the requirements of Salem Unit 2 Technical Specification 3.8.3.1. Salem Unit 2 was operated in Modes 1 through 4, contrary to the requirements of Technical Specification 3.8.3.1. The five circuit breakers had been omitted from testing because the circuit breakers were not listed in the procedure. The cause for the occurrence was a failure to assure that engineering design information for containment penetration overcurrent devices was incorporated into the surveillance procedure. This event is reportable in accordance with 10 CFR 50.73(a) (2) (i) (B), any operation or condition prohibited by the plant's Technical Specifications. NRC FORM 366 (4*95)

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (4*951 LICENSEE EVENT REPORT (LER) TEXT CONTINUATION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER 16) PAGE 13) 05000311 YEAR I seauemAL I UMBER I REVISION NUl\tlER 2 OF 4 SALEM GENERATING STATION UNIT 2 96 - 007 - 00 TEXT Pf more space is required, use additional copies of NRC Form 366Al (171 PLANT AND SYSTEM IDENTIFICATION Westinghouse - Pressurized Water Reactor Reactor Containment Building Penetrations/Circuit Breakers {SAC/52}*

• Energy Industry Identification System (EIIS) codes and component function identifier codes appear as (SS/CCC)

CONDITIONS PRIOR TO OCCURRENCE At the time of identification, Salem Units 1 and 2 were shutdown and defueled. DESCRIPTION OF OCCURRENCE On July 16, 1996, a detailed comparison of surveillance test procedures against engineering calculations identified that five containment penetration conductor overcurrent protective devices {SAC/52} (circuit breakers) had not been demonstrated operable per the requirements of Salem Unit 2 Technical Specification 3.8.3.1. Salem Unit 2 was operated in Modes 1 through 4 contrary to the requirements of Technical Specification 3.8.3.1. The five circuit breakers had been omitted from testing because the circuit breakers were not listed in the procedure. CAUSE OF OCCURRENCE The cause for the occurrence was a failure to assure that engineering design information for containment penetration overcurrent devices was incorporated into the surveillance procedure. PRIOR SIMILAR OCCURRENCES A review of LERs for the past two years identified six LERs in the last two years related to missed Technical Specification Surveillances due to procedure deficiencies. LER 272/96-006 "Missed Independent Verification of Release Lineup on Waste Gas Decay Tanks" identified an occurrence where an independent verification of the release lineup if radiation monitor 1(2)R41C is inoperable. This was caused by a procedure that had the verification step removed during a previous procedure revision. LER 272/96-004 "Technical Specification 4.6.1.1 Incomplete Containment Isolation Valve Position Verification Surveillance" identified an occurrence where Containment Isolation valves were omitted from monthly position verification surveillances due to inadequate implementation of Technical Specification

~urveillance requirements into procedures.

NRC FORM 366A (4-95)

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION 14-951 LiCEi\iSH EVENT REPORT (LER) TEXT CONTINUATION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3) SALEM GENERATING STATION UNIT 2 05000311 YEAR I SEOUEITIAL NUMBER I RrnSIOI Wlol!ER 3 OF 4 96 - 007 - 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17) PRIOR SIMILAR OCCURRENCES (cont'd) LER 272/94-008 "Quarterly Channel Functional Testirg of Position Indication For Power Operated Relief Valves Missed On Both Units" identified an occurrence where a procedure was revised in response to Generic Letter 90-06 without a revision to Technical Specifications which resulted in missed surveillance testing of Power Operated Relief Valves while in Modes 1 and 2. LER 311/95-008, "Technical Specification 4.9.9 Missed Isolation Initiation Testing" identified an occurrence where Containment Purge and Pressure-Vacuum Relief system isolation logic was not fully tested prior to and during Core Alterations due to inadequate implementation of Technical Specification surveillance requirements into procedures. LER 311/96-005-00 "Missed Surveillance of Fuel Handling Building Charcoal Adsorber Test" identified an occurrence where a Salem Unit 2 Fuel Handling Building (FHB) charcoal adsorber sample was tested in October 1995 to Salem Unit 1 acceptance criteria. LER 272/96-005-04 "Technical Specification Surveillance Requirement Implementation Deficiencies" identifies a number of occurrences in which surveillance requirements have not been met due to inadequate implementation. SAFETY CONSEQUENCES AND IMPLICATIONS The failure to test molded case circuit breakers that are credited with p~imary or backup protection of electrical penetrations jeopardizes containment integrity in the event of an overcurrent situation. For a failure to trip coupled with a failure of the alternate protection device and high currents, heat damage and possibly fire at the containment penetration would result. Loss of penetration integrity is assumed in this instance resulting in reduced containment integrity. Since none of the affected penetrations were damaged as a result of the failure to test the circuit breakers, there was no compromise of containment integrity. Therefore, this occurrence did not affect the health and safety of the public. Compensating design features and testing provide some assurance that the penetrations would have been protected for the five untested circuit breakers in the following applications:

1. Emergency Lighting Inverter - 2 breakers (2ELC-1 and 2ELC-3) providing primary protection were not tested. However, the backup breaker (2C2Y) had been tested satisfactorily and based on this, would have functioned if called upon to do so.

2. Fire and Smoke Detection Circuit - 1 breaker (2FP6-11-5) was not tested.

However, the circuit contains a current limiting resistor that reduces the current low enough to ensure penetration integrity in the event of an overcurrent situation. NRC FORM 366A (4-95)

                                                    . .J NRC FO'RM 366A                                                                                                   U.S. NUCLEAR REGULATORY COMMISSION 14-951

' LICENSEE EVENT REPORT (LERI TEXT CONTINUATION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3) 05000311 YEAR I SEOUEllTW. IUMBEI I llEVISKll IUllollEil 4 OF 4 SALEM GENERATING STATION UNIT 2 96 - 007 - 00 TEXT Pf more space is required, use additional copies of NRC Form 366AJ (17) SAFETY CONSEQUENCES AND IMPLICATIONS (cont'd)

3. Radiation Monitoring Circuits - 2 breakers '~1RM35 and 21RM37) were not tested. However, these circuit breakers are backup devices to fuses which constitute the primary protection for the penetration.

CORRECTIVE ACTIONS

1. Conduct the required surveillance testing prior to Unit 2 entry into Mode 4.

2. Complete the review of Unit 1 containment penetration conductor overcurrent procedures to identify other instances of non-compliance due to missing breakers. This review will be completed by September 13, 1996.

3. Complete an evaluation of the engineering review process and interface methods used to assure the accuracy of design engineering information used by Technical Specification procedures by March 31, 1997.

NRC FORM 366A (4-95)}}