ML18102B516

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LER 97-009-00:on 970711,failure to Stroke Pump Discharge Valves for Potential Pressure Locking Concern Was Noted. Caused by Personnel Error.Revised Procedures to Address Addl Instances of CS Pump operation.W/970811 Ltr
ML18102B516
Person / Time
Site: Salem PSEG icon.png
Issue date: 08/07/1997
From: Garchow D, Mel Gray
Public Service Enterprise Group
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-97-009-02, LER-97-9-2, LR-N970499, NUDOCS 9708200050
Download: ML18102B516 (6)


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  • Publ!c Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038-0236 Nuclear Business Unit AUG ll 1997 LR-N970499 U. S. Nuclear Regulatory Commission Document Control. Desk Washington, DC 20555 LER 311/97-009-00 SALEM GENERATING STATION - UNIT 2 FACILITY OPERATING LICENSE NO. DPR-70 DOCKET NO. 50-311 Gentlemen:

This Licensee Event Report entitled "Failure to Stroke Pump Discharge Valves for Potential Pressure Locking Concern" is being submitted pursuant to the requirements of the Code of Federal Regulations 10CFR50. 73 (a) (2) (i) (B) and 10CFR50. 73 (a) (2) (ii) (B).

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  • e&SEBE*

The power is in your hands.

95-2168 REV. 6/94

APPROVED BY OMB NO. 3150-0104 bNRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION (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 LICENSING PROCESS ANO FED BACK TO INDUSTRY. FORWARD LICENSEE EVENT REPORT (LER) COMMENTS REGARDING BURDEN ESTIMATE TO THE INFORMATION AND RECORDS MANAGEMENT BRANCH (T~ F33), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555--0001, ANO TO (See reverse for required number of THE PAPERWORK REDUCTION PROJECT (3150--0104), OFFICE OF MANAGEMENT ANO BUDGET, WASHINGTON, DC 20503.

digits/characters for each block)

FACILITY NAllE (1) DOCKET NUllBER (2) PAGE (3)

SALEM GENERATING STATION, UNIT 2 05000311 1 of 5 TITLE (4) I FAILURE TO STROKE PUMP DISCHARGE VALVES FOR POTENTIAL PRESSURE LOCKING CONCERN EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (8)

MONTH DAY YEAR YEAR I SEQUENTIAL NUMBER IREVISION NUMBER MONTH DAY YEAR FA,CILITY NAME Salem, Unit 2 DOCKET NUMBER 05000311 FACILITY NAME DOCKET NUMBER 07 11 97 97 - 009 - 00 08 7 97 OPERATING ~!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) x 50. 73(a)(2)(ii) 50. 73(a)(2)(x)

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)

Mel Gray, Licensing Engineer 609-339-2191 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TONPRDS TONPRDS SUPPLEMENTAL REPORT EXPECTED (14) EXPECTED MONTH DAY YEAR SUBMISSION

'YES (If yes, complete EXPECTED SUBMISSION DATE). x'NO DATE (15)

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

Technical Specification 3.6.2.1, which requires both Containment Spray (CS) systems to be operable in Modes 1 through 4, was not satisfied from June 15, 1997 to July 14, 1997. The CS pump discharge valves (21CS2 & 22CS2) were identified as susceptible to pressure locking in PSE&G'*s response to Generic Letter 95-07. To address pressure locking concerns, the CS2 valves are required to be .stroked following operation of the associated CS pump. On July 11, 1997, it was identified that procedure S2.0P-IO.ZZ-0002, "Cold Shutdown to Hot Standby," directed functional testing of the CS pumps without subsequently stroking the 21CS2 and 22CS2. Further review determined that the CS pumps were functionally tested on June 14, 1997 in accordance with this procedure while in Mode 5. Valves 21CS2 and 22CS2 were not stroked open and closed prior to June 15, 1997 when Salem Unit 2 entered Mode 4. The cause of this occurrence is attributed to person~el error in that personnel failed to perform an adequate review to identify all instances in which the Containment Spray pumps were operated. Corrective actions include procedure revisions to address the additional instances of Containment Spray pump operation. This event is reportable in accordance with 10 CFR 5 0. 7 3 (a) ( 2) ( i) ( B) , any condition prohibited by the plant's Technical Specifications, and 10 CFR 50.73 (a) (2) (ii) (B) a condition that was outside the design basis of the plant.

NRC FORM 366 (4-95)

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

.....1 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 5 SALEM GENERATING STATION UNIT 2 97 - 009 - 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

PLANT AND SYSTEM IDENTIFICATION Westinghouse - Pressurized Water Reactor Containment Spray System {BE/V}

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

CONDITIONS PRIOR TO OCCURRENCE At the time of identification, Salem Unit 2 was in Mode 4, Hot Shutdown DESCRIPTION OF OCCURRENCE Technical Specification 3.6.2.1 states, "Two independent containment spray systems shall be OPERABLE with each spray system capable of taking suction from the RWST and transferring suction to the RHR pump discharge." "With one containment spray system inoperable, restore the inoperable spray system to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hou~s; restore the inoperable spray system to.OPERABLE status within the next 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be 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 />."

In response to Generic Letter 95-07, "Pressure Locking and Thermal Binding of Safety-Related Power-Operated Gate Valves," PSE&G identified that the Containment Spray (CS) pump discharge valves (11CS2, 12CS2, 21CS2, 22CS2) were susceptible to pressure locking. In letter LR-N96035 dated February 13, 1996, PSE&G stated that "Pressure locking of the CS2 valves will be addressed by a surveillance test procedure change to cycle the valves after the system has been depressurized." The action to be taken to address potential pressure locking concerns was to manually stroke the CS2 valves following operation of the associated Containment Spray pump. Surveillance procedures were revised to include stroking of the CS2 valves after shutdown of the Containment Spray pumps.

On July 11, 1997, the Salem Technical Specification Surveillance Improvement Project (~SSIP) identified that procedure S2.0P-IO.ZZ-0002, "Cold Shutdown to Hot Standby," directed functional testing of the Containment Spray pumps without specifying that stroking of the pump discharge valves (21CS2 & 22CS2) was required following operation of the pumps. A review of the recent Mode transition for Salem Unit 2 which utilized S2.0P-IO.ZZ-0002 (IOP-2), indicated that the Containment Spray pumps were functionally tested on June 14, 1997 while in Mode 5 to demonstrate proper electrical alignment. Subsequently, on June 15, 1997, Salem Unit 2 entered Mode 4. Valves 21CS2 & 22CS2 were not stroked open and closed following functional testing of the Containment Spray pumps until June 16, 1997 (21CS2) and July 14, 1997 (22CS2). In accordance with Technical Specification 3.6.2.1, both Containment Spray systems are required to be 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)

SALEM GENERATING STATION UNIT 2 0 5 0 0 0 311 YEAR I SEQUENTIAL NUMBER IREVISION NUMBER 3 OF 5 97 - 009 - 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17) operable in Modes 1 through 4. Thus, the requirements of Technical Specification 3.6.2.1 were not satisfied for the period from June 15, 1997 to July 14, 1997. In addition, the UFSAR Chapter 15 accident analysis assumes operation of the spray system. If the CS2 valves had failed to open due to pressure locking of the disc, Containment Spray would not have actuated and the assumptions and conclusions of the Chapter 15 analysis would not have been met.

A review of the implementation of this commitment identified that initially, only the Containment Spray pump surveillance test procedures were identified for revision to address stroking the CS2 valves following pump operation. A word search of procedures during revision of the pump surveillance procedures identified several additional surveiliance procedures which started the Containment Spray pumps. A total of 14 Unit 1 and 2 surveillance procedures (7 per Unit) were identified. However, IOP-2 was not identified as one of the procedures which operated the Containment Spray pumps. As a result, the procedure was not revised to stroke the CS2 valves open and closed following operation of the Containment Spray pumps.

Further review of the condition identified that post-maintenance testing for certain maintenance activities (breaker PMs, etc.) presented additional opportunities for the Containment Spray pumps to be operated without proper stroking of the CS2 valves.

This event is reportable in accordance with 10 CFR 50.73(a) (2) (i) (B), any condition prohibited by the plant's Technical Specifications, and 10 CFR 50.73 (a) (2) (ii) (B) a condition that was outside the design basis of the plant.

CAUSE OF OCCURRENCE The cause of this occurrence is attributed to personnel error. Following the evaluation of Generic Letter 95-07, personnel failed to perform an adequate review to identify all instances in which the Containment Spray pumps were operated.

PRIOR SIMILAR OCCURRENCES A review of LERs for Salem Units 1 and 2 over the last two years identified three similar occurrences.

LER 272/97-008 addressed the failure to adequately implement the requirements of Generic Letter 90-06 with regard to testing Power Operated Relief Valve (PORV) accumulator solenoid valves and check valves.

LER 272/96-026 addressed the failure to adequately test check valves in the Residual Heat Removal hot leg flow path. The guidance contained in Generic Letter 89-04 on acceptable testing methods for full flow check valves was not adequately incorporated into the In Service Test program for the RH27 valves.

NRC FORM 366A (4-95))

NRC FORM 366A U.

  • NUCLEAR REGULATORY COMMISSION (4-95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3)

SALEM GENERATING STATION UNIT 2 0 5 0 0 0 311 YEAR I SEQUENTIAL NUMBER IREVISION NUMBER 4 OF 5 97 - 009 - 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

LER 272/96-015 identified degradation of CFCU performance, in part due to inadequate implementation of GL 89-13 commitments.

SAFETY SIGNIFICANCE If the Containment Spray valves fail to open following a design basis accident, Containment temperature and pressure could exceed design limits if all five fan cooling units are not operating. Pressure locking of, a CS2 valve could render the associated Containment Spray system inoperable. The analyses of the CS2 valves performed to address Generic Letter 95-07 considered worst case scenarios which included degraded voltage and maximum pressure locking. Bus voltages were within the normal range during the period from June 14, 1997 through July 14, 1997. During the functional test of the Containment Spray pumps, each pump was operated very briefly, long enough to verify the breaker was supplying power to II the motor, and then the pump was stopped. The 21CS2 valve was stroked on June ii 16, 1997; within three days of pump operation, and within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> of entering ,,11" Mode 4. The valve stroked without incidence which indicated the absence of pressure locking at the time of valve stroking. The 21CS2 valve was stroked without incidence on July 14, 1997. It is unlikely that the CS2 valves were sub]ected to pressure locking conditions as a result of the functional test activity. The health and safety of the public were not affected. The safety significance of this occurrence is considered minimal.

CORRECTIVE ACTIONS

1. S2.0P-IO-ZZ-0002 was revised to stroke the CS2 valves open and closed following functional testing of the Containment Spray pumps.
2. Sl.OP-IO-ZZ-0002 will be revised to address CS2 valve stroking prior to Unit 1 entry into Mode 5.
3. A preliminary review was performed of work activities associated with the Containment Spray pump breakers. The review identified that retesting following Containment Spray pump breaker preventative maintenance activities presented an opportunity for the pumps to be operated without stroking the CS2 valves. Further review will be performed to determine if any additional activities could result in operation of the Containment Spray pumps without stroking the CS2 valves. Based on the results of this review, actions will be taken to ensure that retest activities will include stroking of the CS2 valves if the associated Containment Spray pump is operated. This review and implementation of associated corrective actions will be completed by October 1, 1997.

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)

SALEM GENERATING STATION UNIT 2 0 5 0 0 0 311 YEAR I SEQUENTIAL NUMBER IREVISION NUMBER 5 OF 5 97 - 009 - 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

4. A review of PSE&G's response to Generic Letter 95-07 was performed to determine if any additional valves were required to be stroked to address pressure locking or thermal binding concerns. The review confirmed that the CS2 valves were the only valves which utilized administrative controls to address pressure locking concerns.
5. Required Reading has been issued to Operations Department personnel to make them aware of the Generic Letter 95-07 commitment related to CS2 valve stroking.
6. Personnel responsible for the inadequate commitment implementation will be held accountable for their actions in accordance with the PSE&G disciplinary process.

NRC FORM 366A (4-95))