ML18102A421

LER 96-004-01:on 960307,surveillance Was Missed for Salem Generating Station.Caused by Lack of Adequate Control for Development & Maintenance of TS Surveillance Procedures. License Change Will Be submitted.W/960920 Ltr

ML18102A421
Person / Time
Site:	Salem
Issue date:	09/20/1996
From:	Garchow D, Bernard Thomas Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-96-004-01, LER-96-4-1, LR-N96301, NUDOCS 9609300108
Download: ML18102A421 (7)

Text

e OPS~G Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038-0236 Nuclear Business Unit SEP 2 0 1996 LR-N96301 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

LER 272/96-004-01 SALEM GENERATING STATION - UNIT 1 FACILITY OPERATING LICENSE NO. DPR-70 DOCKET NO. 50-272 This Licensee Event Report Supplement entitled "Containment Isolation Valve Missed Technical Specification Surveillance" is being submitted pursuant to the requirements of the Code of Federal Regulations 10CFR50. 73 (a) (2) (i) (B).

QOlyf. lfau~

David F. Garcnow General Manager -

Salem Operations Attachment SORC Mtg. 96- 129 BJT/

C Distribution LER File 3.7 9609300108 960920 ,,.,.-

PDR ADOCK 05000272 S PDR The r0wer is in \'Ollr hands.

.l' l .

95-2168 REV. 6/94

NRCFORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150-0104 (4-95) EXPIRES 04/30198 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS MANDATORY INFORMATION COLLECTION REQUEST: 50.0 HRS.

REPORTED LESSONS LEARNED ARE INCORPORATED INTO THE LICENSEE EVENT REPORT (LER) LICENSING PROCESS ANO FED BACK TO INDUSTRY. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE INFORMATION ANO RECORDS MANAGEMENT BRANCH (T-8 ~NUCLEAR (See reverse for required number of REGULATORY COMMISSION, WASHINGTON, DC , ANO TO THE PAPERWORK REDUCTION PROJECT (3150-0104), OFFICE OF digits/characters for each block) MANAGEMENT ANO BUDGET, WASHINGTON, DC 20503.

FACILITY NAME (1) DOCKET NUMBER (2) PAGE (3)

SALEM GENERATING STATION UNIT 1 05000272 1 OF 6 TITLE (4)

Containment Isolation Valve Missed Technical Specification Surveillance EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (8)

FACILITY NAME DOCKET NUMBER MONTH DAY YEAR YEAR I SEQUENTIAL NUMBER I REVISION NUMBER MONTH DAY YEAR Salem, Unit 2 FACILITY NAME 05000311 DOCKET NUMBER 03 07 96 96 - 004 - 01 09 20 96 OPERATING N THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check one or more) (11)

MODE (9) 20.2201(b) 20.2203(a)(2)(v) x 50. 73(a)(2)(i) 50. 73(a)(2)(viii)

POWER 20.2203(a)(1) 20.2203(a)(3)(i) 50. 73(a)(2)(ii) 50. 73(a)(2)(x) 000 LEVEL (10) 20.2203(a)(2)(i) 20.2203(a)(3)(ii) 50. 73(a)(2)(iii) 73.71 20.2203(a)(2)(ii) 20.2203(a)(4) 50. 73(a)(2)(iv) OTHER 20.2203(a)(2)(iii) 50.36(c)(1) 50. 73(a)(2)(v) Spec~in Abstract below or in C Form 366A 20.2203(a)(2)(iv) 50.36(c)(2) 50. 73(a)(2)(vii)

LICENSEE CONTACT FOR THIS LER (12)

NAME TELEPHONE NUMBER (Include Area Code)

Brian Thomas, Licensing Engineer 609-339-2022 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TONPRDS 1::1i::=:=l!l:il=llll:llll: TONPRDS Ives SUPPLEMENTAL REPORT EXPECTED (14)

(If yes, complete EXPECTED SUBMISSION DATE).

I XINO EXPECTED SUBMISSION DATE (15)

MONTH DAV VEAR ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) (16)

On March 7, 1996, it was identified that the requirements of Technical Specification 4. 6 .1.1 were not fully implemented at Units 1 and 2

• Specifically, the monthly surveillance procedure that has been used to implement Technical Specification 4. 6 .1.1 did not direct position verification of the Refueling Canal Supply and Discharge Containment Isolation Valves. This condition has existed since at least 1986.

The apparent cause of this occurrence is attributed to a lack of adequate controls for the development and maintenance of Technical Specification surveillance procedures. This weakness was previously identified in LER 311/95-008. Corrective actions as stated in this previous LER are still in progress, and will include verification of the adequacy of all Technical Specification surveillance procedures, with limited exceptions, and verification that controls are in place to maintain the adequacy of the procedures.

This event is reportable in accordance with 10 CFR 50.73 (a) (2) (i) (B) I any condition prohibited by the plant's Technical Specifications.

NRC FORM 366 (4-95)

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (4-95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3) 05 0002 7 2 YEAR I SEQUENTIAL NUMBER IREVISION NUMBER 2 OF 6 SALEM GENERATING STATION UNIT 1 96 - 004 - 01 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

PLANT AND SYSTEM IDENTIFICATION Westinghouse - Pressurized Water Reactor Waste Disposal Liquid System (WL)

Chemical and Volume Control System (CB)

Safety Injection System (BQ)

Containment Spray System (BE)

Main Steam System (SB)

IDENTIFICATION OF OCCURRENCE Discovery Date: March 7, 1996 Event Dates: The failure to perform adequate, documented verification of the referenced containment isolation valves occurred during each required surveillance interval, possibly since initial licensing, with the plants in Modes 1 through 4.

CONDITIONS PRIOR TO OCCURRENCE At the time of identification, Salem Units 1 and 2 were shutdown and defueled. The Technical Specification surveillance Mode applicability is 1 through 4.

DESCRIPTION OF OCCURRENCE Technical Specification 4.6.1.1 states, "Primary CONTAINMENT INTEGRITY shall be demonstrated at least once per 31 days by verifying that all penetrations not capable of being closed by OPERABLE containment automatic isolation valves and required to be closed during accident conditions are closed by valves, blind flanges, or deactivated automatic valves secured in their positions, except as provided in Table 3.6-1 of Specification 3.6.3.1, and all equipment hatches are closed and sealed."

In response to questions raised during the NRC Restart Assessment Team Inspection at Hope Creek, Salem Station initiated a review of its procedure for containment isolation valve position verification. The review identified four valves (1WL190, 1WL191, 2WL190, and 2WL191) that were not included in the monthly (31 day) Containment Isolation Valves surveillance procedure. A random sampling of historical records showed that the valves had been missing from the surveillance tests at both units since at least 1986. The valves have been listed in Table 3.6-1 of the Unit 1 and 2 Technical Specifications since the licenses were issued.

NRC FORM 366A (4-95)

NRC FORM 388A U.S. NUCLEAR REGULATORY COMMISSION (4-95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (8) PAGE (3) 05000272 YEAR I SEQUENTIAL NUMBER IREVISION NUMBER 3 OF 6 SALEM GENERATING STATION UNIT 1 96 - 004 - 01 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

DESCRIPTION OF OCCURRENCE (cont'd)

As part of corrective action 1 of LER 272/96-004-00, a review of the Salem Unit 2 containment isolation valves (CIVs) was performed to assure that CIVs were properly identified and tested. This review identified that Unit 2 manual valves CV291, GB18, MS130, MS55, MS201, MS199, VC24, and VC25 are within the containment isolation boundary; however, these valves were not included in periodic position verification procedures. The review also determined that valve 21VC20 was incorrectly identified in Technical Specification Table 3.6-1 as valve 21SF20. It was also determined by this review that valves 2SJ71, the Fuel Transfer Tube, 2CS903, and 2CV98 are not CIVs although they are listed on Technical Specification Table 3.6-1.

Technical Specification Table 3.6-1 also identifies valves CV68 and CV69 as Phase A CIVs; however, these valves only isolate on a Safety Injection Signal ("S" signal) as stated in the UFSAR. The Phase A isolation signal is either generated from the "S" signal or from a sensed containment high pressure which is also an input for safety injection actuation.

APPARENT CAUSE OF OCCURRENCE The apparent cause of this occurrence is attributed to a lack of adequate controls for the development and maintenance of Technical Specification surveillance procedures and inadequate design review during the development of Technical Specification Table 3.6-1. This weakness was previously identified in LER 311/95-008.

PRIOR SIMILAR OCCURRENCES A review of LERs for Salem Units 1 and 2 issued in the last two years identified eight LERs (272/94-008, 272/96-005, 272/96-007, 311/95-008, 311/96-002, 311/96-003, 311/96-009, and 272/96-019) that were a result of missed surveillances due to inadequate implementation of Technical Specification requirements. The corrective actions were specific to the missed surveillance issues addressed in each LER. The identification of these programmatic issues resulted in the initiation of the Technical Specification Surveillance Improvement Program (TSSIP) described in LER 311/95-008. The TSSIP should ensure that Technical Specification surveillance requirements are adequately proceduralized.

NRC FORM 366A (4-95)

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (4-95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3) 05000272 YEAR I SEQUENTIAL NUMBER IREVISION NUMBER 4 OF 6 SALEM GENERATING STATION UNIT 1 96 - 004 - 01 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

DESCRIPTION OF OCCURRENCE (cont'd)

SAFETY CONSEQUENCES AND IMPLICATIONS Administrative controls such as post outage valve lineup checks would likely have ensured that the 1(2)WL190 & 1(2)WL191 valves were properly shut prior to power operations following an outage. Additionally, the monthly surveillance procedures included position verification of the outside Containment Refueling Canal Supply and Discharge isolation valves (1SF22, 1SF36, 2SF22, and 2SF36). Thus there were no safety consequences associated with this condition since containment integrity would not have been affected in the unlikely event of an accident.

Testing was performed for valve 21VC20 and is currently being performed that meets the Technical Specification surveillance testing required for this CIV, thus there were no safety consequences associated with this condition.

For CV291, VC24, and VC25 administrative controls such as post outage valve lineup check would likely have ensured that these valves were properly shut prior to power operations following an outage. Thus there was no safety consequences associated with this condition since containment integrity would not have been affected in the unlikely event of an accident.

The MS199 is a manual valve that supplies the Main Steam strut pipe heating system. This valve remains open to support the proper operation of the Main Steam Safety Valves. The MS55 and MS201 valves are one inch manual drain valves off of the steam supply lines to the turbine driven auxiliary feedwater pump. These valves remain open during normal operation to ensure removal of condensate to assure operation of the turbine without the presence of water slugs. The MS130 is a manual valve that remains open to provide a continuous supply to the Main Steam radiation monitors and secondary side sampling. PSE&G is currently evaluating the impact of these valves remaining open during normal operation. Preliminary results of analyses being performed to support the Control Area Ventilation Upgrade project indicate that the offsite doses from the Steam Generator Tube Rupture and Main Steam Line Break events will remain well within the guidelines of 10CFR100. Additionally, the preliminary results also indicate that control room doses remain within the guidelines of GDC 19.

NRC FORM 366A (4-95)

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (4-95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3) 05000272 YEAR I SEQUENTIAL NUMBER I REVISION NUMBER 5 OF 6 SALEM GENERATING STATION UNIT 1 96 - 004 - 01 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

SAFETY CONSEQUENCES AND IMPLICATIONS (cont'd)

Although the GB18 valves were not included in the surveillance test procedure for containment integrity, valve GB19 which is a manual valve downstream of the GB18s was included in the surveillance procedure for position verification. Thus there were no safety consequences associated with this condition since containment integrity would not have been affected in the unlikely event of an accident.

Although valves CV68 & CV69 do not receive a direct Phase A isolation signal, these valves close on a Safety Injection Signal which generates a Phase A isolation. The only direct automatic actuation for Phase A isolation is from a sensed containment high pressure. The sensed containment high pressure will also generate a safety injection actuation signal. The CV68 and CV69 valves are surveilled in accordance with their technical specification frequency to isolate on a safety injection signal.

Thus there is no safety significance associated with this condition since the valves will isolate in the unlikely event of an accident.

CORRECTIVE ACTIONS

1) A review is being performed to ensure that all containment isolation valves are included, as required, in the periodic position verification surveillance tests. This review will also verify the proper isolation signals for Phase A, and Phase B containment isolation valves. This review will be complete prior to restart of the Salem Unit 1. The review of Salem Unit 2 containment isolation valves for periodic position verification has been completed. The review of Unit 2 Phase A and Phase B containment isolation valve signals will be completed prior to restart of Salem Unit 2.

2) 1WL190, 1WL191, 2WL190, and 2WL191 wer.e added to the appropriate monthly 1 surveillance procedures. I

3) A Technical Specification Surveillance Improvement Project (TSSIP) has been initiated for Salem Units 1 and 2. The scope and content of the TSSIP program was described previously in LER 311/95-008-00. The TSSIP review is expected to be complete by December 31, 1997.

4) PSE&G is currently evaluating the impact of manual valves MS199, MS55, MS201, and MS130 remaining open during normal operation and will complete this evaluation by October 15, 1996.

5) Unit 2 valves CV291, GB18, VC24, and VC25 were added to the appropriate surveillance procedures.

NRG FORM 366A (4-95)

"'~lrr============-~================================================~':'=====:=?===========~===========;i NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION

• ~ (4-95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3) 05 00027 2 YEAR I SEQUENTIAL NUMBER l REVISION NUMBER 6 OF 6 SALEM GENERATING STATION UNIT 1 96 - 004 - 01 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

CORRECTIVE ACTIONS (cont'd)

6) A License Change Request will be submitted for Salem Unit 2 by October 1, 1996, to relocate Technical Specification Table 3.6-1 for CIVs to the UFSAR.

NRC FORM 366A (4*95)