ML18102B461

LER 97-007-00:on 970623,TS 4.0.5 ISI Requirement to Perform Radiography of Check Valves 2CC195 & 2CC210 Every 92 Days Determined to Have Been Missed.Caused by Personnel Error. Check Valves Subsequently tested.W/970723 Ltr

ML18102B461
Person / Time
Site:	Salem
Issue date:	07/23/1997
From:	Garchow D, Bernard Thomas Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-97-007-01, LER-97-7-1, LR-N970456, NUDOCS 9707300043
Download: ML18102B461 (5)

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. Public _Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038-0236 Nuclear Business Unit JUL 2 3 1997 LR-N970456 U. S. Nuclear Regulatory Commission Document Contr61 Desk Washington, DC 20555 Gentlemen:

LER 311/97-007-00 SALEM GENERATING STATION - UNIT 2 FACILITY OPERATING LICENSE NO. DPR-75 DOCKET NO. 50-311 This Licensee Event Report entitled "Missed 4.0.5 Testing of Check Valves 2CC195 and 2CC210," is being submitted pursuant to the requirements of the Code of Federal Regulations 10CFR50. 73 (a) (2) (i) (B).

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David F. Garchow General Manager -

Salem Operations Attachment BJT C Distribution LER File 3.7 9707300043 970723 PDR ADOCK 05000311 S PDR

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95*2168 REV. 6/94

NRCFORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150-0104 (4-95) EXPIRES 04/30/98 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 AND FED BACK TO INDUSTRY. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE INFORMATION AND RECORDS MANAGEMENT BRANCH (T-6 F33), U.S. NUCLEAR (See reverse for required number of REGULATORY COMMISSION, WASHINGTON, DC 20555--0001, AND TO THE PAPERWORK REDUCTION PROJECT (3150--0104), OFFICE OF digits/characters for each block) MANAGEMENT AND BUDGET, WASHINGTON, DC 20503.

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

SALEM GENERATING STATION UNIT 2 05000311 1 OF 4 TITLE(.()

Missed 4.0.5 Testing of Check Valves 2CC195 and 2CC210 EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (8)

MONTH DAY YEAR YEAR SEQUENTIAL IREVISION MONTH DAY YEAR FACILITY NAME DOCKET NUMBER I NUMBER NUMBER FACILITY NAME DOCKET NUMBER 06 23 97 97 - 007 - 00 07 23 97 OPERATING 4 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 000 20.2203(a)(1) 20.2203(a)(3)(i) 50. 73(a)(2)(ii) 50. 73(a)(2)(><)

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 J. 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 TO NPRDS TONPRDS SUPPLEMENTAL REPORT EXPECTED (14) EXPECTED MONTH DAY YEAR SUBMISSION

'YES (If yes, EXPECTED SUBMISSION DATE). XINO complete DATE (15)

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

On June 23, 1997 ,- *the Technical Specification (TS) 4. 0. 5 Inservice Inspection (ISI) requirement to perform radiography of check valves 2CC195 and 2CC210 every 92 days was determined to have been missed. As a result of the missed surveillance, one loop of the component cooling water was declared inoperable until the surveillance testing (radiography) was completed. Since the missed surveillance test exceeded the surveillance test interval, the 25% extension allowed by TS 4. 0. 2' and the Limiting Condition for Operation (LCO) statement time, this event is reportable in accordance with 10CFR50.73(a) (2) (i) (B) as, "any condition prohibited by the plant's Technical Specifications."

The cause of this occurrence is attributed to personnel error. The recurring task for performing the next 92 day surveillance was not generated prior to the expiration of the surveillance test interval. The check valves were subsequently tested and determined to be in their proper position. The personnel involved in this event have received appropriate disciplinary actions.

NRC FORM 366 (4-95)

~ t NRC FORM 366A (4-95)

U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3) 05000311 YEAR I SEQUENTIAL NUMBER IREVISION NUMBER 2 OF 4 SALEM GENERATING STATION UNIT 2 97 - 007 - 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

PLANT AND SYSTEM IDENTIFICATION Westinghouse - Pressurized Water Reactor Component Cooling Water System {CB/-}*

• Energy Industry Identification System (EIIS) codes and component function identifier codes appear as {SS/CCC} in the text.

CONDITIONS PRIOR TO OCCURRENCE The plant was in Mode 4 prior to the event.

DESCRIPTION OF OCCURRENCE On June 23, 1997, the Technical Specification (TS) 4.0.5 Inservice Inspection (ISI) requirement to perform radiography of check valves 2CC195 and 2CC210 every 92 days was determined to have been missed. The 92 day surveillance plus the 25% surveillance extension provided by TS 4.0.2 was due on June 15, 1997. Upon identification of the overdue surveillance for the 2CC195 and 2CC210 valves, the check valves were radiographed on June 23, 1997, and were determined to be in their proper position (closed). As a result of the missed surveillance, one loop of the component cooling water was declared inoperable until the surveillance testing (radiography) was completed. Since the missed surveillance test exceeded the surveillance test interval, the 25% extension allowed by TS 4.0.2, and the Limiting Condition for Operation (LCO) statement time, this event is reportable in accordance with 10CFR50.73(a) (2) (i) (B) as, "any condition prohibited by the plant's Technical Specifications."

ANALYSIS OF OCCURRENCE In February of 19if7, the Inservice Testing (IST) group identified that check valves 1(2)CC195 and 1(2)CC210 for the component cooling system were required to be tested in the reverse direction for ASME Class 3 boundary isolation on a 92 day frequency. As a result of the identification of the requirement to test check valves CC195 and CC210 in the closed position, valves 2CC195 and 2CC210 were radiographed on February 21, 1997 to verify that they were fully closed and fulfilling their function as the ASME Class 3 boundary. Completion of the radiography on February 21 then started the 92 day surveillance interval for the next surveillance test. The past reportability for failure to perform surveillance testing of the CC195 and CC2LO valves prior to February of 1997 will be addressed in Supplemental LER 272/97-001-01.

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) 0 5 0 0 0 311 YEAR I SEQUENTIAL NUMBER I REVISION NUMBER 3 OF 4 SALEM GENERATING STATION UNIT 2 97 - 007 - 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

ANALYSIS OF OCCURRENCE (cont'd)

As a result of the identification of the need to perform surveillance testing of check valves CC195 and CC210, a Business Process Action Request (BPAR) was generated by the ISI group, on April 2, 1997, to request that surveillance test recurring tasks (RT) for valves 2CC195 and 2CC210 be generated to test these check valves on a 92 day frequency. The valves were then added to the ISI procedure for radiography on April 4, 1997. Although the request for generation of the surveillance test RTs was generated in April, the request was not received by the Technical Specification Administrator, who is responsible for implementing changes to the surveillance testing RT, until May 6. The surveillance test recurring task request generated by the ISI group did not identify when the previous surveillance test was performed or when the next surveillance test was required to be performed in accordance with the administrative procedure. Although the date for required completion of the next surveillance test was not specified in the description of the BPAR, the Technical Specification Administrator, by coincidence, assigned a completion date for creation of the new surveillance testing RT of June 15, 1997 (this date corresponds to the 92 day surveillance interval plus the 25% extension allowed by TS 4.0.2). However, the task for completion of the new surveillance testing RT was extended by the Technical Specification Administrator to June 27, 1997, without the recognition that the surveillance test would go overdue. Upon generation of the request for creation of the new surveillance test RT, the ISI group also did not verify that the recurring task would be issued prior to the due date of the next required surveillance test.

Upon identification that the 4.0.5 surveillance testing for 2CC195 and 2CC210 was overdue, the check valves were radiographed on June 23, 1997 and the new surveillance testing RT was generated on June 25, 1997.

CAUSE OF OCCURRENCE - -~

The cause of this occurrence is attributed to personnel error. The ISI group did not verify that the new surveillance testing RT would be generated prior to the due date of the next surveillance test. Also, the Technical Specification Administrator extended the task for generation of the new surveillance testing RT without recognizing that the next surveillance test would go overdue.

PRIOR SIMILAR OCCURRENCES A review of LERs for Salem Units 1 and 2 submitted in the past two years did not identify any additional reportable occurrences as a result of the failure to generate a recurring task for creation of surveillance testing work orders.

Although numerous LERs have been written in the past two years for missed surveillance testing, these incidents have been attributed to a lack of adequate controls on the development and maintenance of Technical Specification surveillance procedures.

NRG FORM 366A (4-95)

-f NRC FORM 366A (4-95)

U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3) 05000311 YEAR I SEQUENTIAL NUMBER I REVISION NUMBER 4 OF 4 SALEM GENERATING STATION UNIT 2 97 - 007 - 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

SAFETY SIGNIFICANCE The testing of check valves 2CC195 and 2CC210 on June 23, 1997, demonstrated that the check valves were closed and provided the proper ASME Code boundary.

Therefore there was no impact to the health and safety of the public.

CORRECTIVE ACTIONS

1. Check valves 2CC195 and 2CC210 were radiographed on June 23, 1997 and determined to be in their proper position (closed position).

2. The recurring task for generation of the next surveillance tests for 2CC195 and 2CC210 on a 92 day frequency was issued on June 25, 1997.

3. A review of outstanding surveillance testing recurring task change requests was performed to determine if any further surveillance testing was overdue.

The review identified that no other surveillance testing was overdue.

4. A review of the administrative controls for creation and revision to surveillance testing recurring tasks is being performed to determine if further enhancements to the administrative controls are required. This review will be completed by October 31, 1997.

5. A Station Key Message will be distributed to NBU department personnel, reemphasizing the information required by NC.NA-AP.ZZ-0012, "Technical Specifications Surveillance Program," for generation of surveillance testing recurring task changes. This Key Message will be distributed by July 28, 1997.

6. Appropriate disciplinary actions were taken in accordance with PSE&G's policies for the - -~

Technical Specification Administrator.

7. Appropriate disciplinary actions were taken in accordance with PSE&G'S policies for the ISI personnel involved in this event.

NRC FORM 366A (4-95)