ML18106A882

LER 98-013-00:on 980820,noted Surveillance of Containment Penetration Overcurrent Protection Devices Missed.Caused by Human Error.Satisfactorily Tested Apprpriate Breakers & Disciplined Involved Personnel.With 980921 Ltr

ML18106A882
Person / Time
Site:	Salem
Issue date:	09/21/1998
From:	Bakken A, Enrique Villar Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-98-013-01, LER-98-13-1, LR-N980454, NUDOCS 9809290161
Download: ML18106A882 (6)

Text

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• Public ~ervice ~lectric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038-0236 Nuclear Business Unit SEP 211998 LR-N980454 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

LER -311 /98-013-00 SALEM GENERATING STATION -UNIT 2 FACILITY OPERATING LICENSE NO. DPR-75 DOCKET. NO. 50-311 This Licensee Event Report "Missed Surveillance of Containment Penetration Overcurrent Protection Devices" is being submitted pursuant to the requirements of the Code of Federal Regulations 10CFR50.73(a)(2)(i)(B).

Sincerely, A. C. Bakken Ill General Manager -

Salem Operations Attachment

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/EHV. .....,. ..... i C Distribution LER File 3.7 9809290161 980921 t"-*

PDR ADOCK 05000311 '*.

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The power is in your hands.

95-2168 REV. 6/94

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NRCFORM366 U.S.N R REGULATORY COMMISSION /{. OVED 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.

COMMENTS REGARDING BURDEN ESTIMATE TO THE INFORMATION FORWARD AND RECORDS MANAGEMENT BRANCH ~T-6 F33), U.S. NUCLEAR (See reverse for required number of REGULATORY COMMISSION, WASHINGTON, C 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 5 TITLE(4)

Missed Surveillance of Containment Penetration Overcurrent Protection Devices EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (8)

FACILITY NAME DOCKET NUMBER MONTH DAY YEAR SEQUENTIAL I REVISION MONTH DAY YEAR YEAR I NUMBER . NUMBER Salem Unit 1 05000272 FACILITY NAME DOCKET NUMBER 08 20 98 98 - 013 - 00 09 21 98 05000 THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check one or more) (11)

) 1 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)

LEVEL (10) 100 20,2~Q~(a)(2)(i)

• 20.2203(a)(3)(ii) 50. 73(a)(2)(iii) 73.71 20.2203(a)(2)(ii) 20.2203(a)(4) so,73(a)(2)(iv) OTHER 20.2203(a)(2)(iii) 50.36(c)(1) 50. 73(a)(2)(v) Spec~ln 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)

E. H. Villar Senior Licensing Engineer 609 - 339- 5456 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 IYES (If yes, complete EXPECTED SUBMISSION DATE). -

• XINO DATE (15)

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

On August 20, 1998, a condition adverse to quality (CAQ) was identified relative to Technical Specifications (TS) 3,8.3.1 for Salem Unit 2. The CAQ identified that a group of low voltage conductor overcurrent protective devices (circuit breakers) had not.been demonstrated operable per the requirements of Salem Unit 2 TS surveillance requirement 4 . 8 . 3. 1. a2 . This TS requires that all containment penetration conductor overcurrent protective devices be operable. Specifically, surveillance 4.8.3.1 a2 requires that at least 10% of each breaker type be tested every 18 months.

None of the breakers in this type had been tested within the 18 months plus 25% frequency required by TS. One additional breaker, of a different type, was identified as not having been tested during the investigation. The apparent cause of this report is attributed to human error. Appropriate breakers were satisfactorily tested, and a level one-root cause investigation team was established.

Therefore, this event is reportable per 10CFR50.73 (a) ( 2) (I) ( B ) .*

NRC FORM 366 (4-95)

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NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION

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,,, LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACiLITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3) 05000311 YEAR I SE~Ur.i~~L I~ 2 OF 5 SALEM GENERATING STATION UNIT 2 98 - 013 - 00 TEXT (If more space is required, use additional copies of NRC Fonn 366A) (17)

PLANT IDENTIFICATION:

Westinghouse - Pressurized Water Reactor Reactor Containment Buii~ing Penetrations/Circuit Breakers {SAC/52}*

DC Power * {EJ/ }

Low Voltage Power System - Class lE {EB/

• Energy Industry Identification System (EIIS) codes and component function identifier codes app~ear . as (SS/CCC)

IDENTIFICATION OF OCCURRENCE:

Date of Occurrence: August 20, 1998 Date of Identification: August 20, 1998 Report Date: September 21, 1998 CONDITIONS PRIOR TO OCCURRENCE:

At the time of- identification; Salem Unit 2-was in Mode 1 at 100% power.

DESCRIPTION OF OCCURRENCE:

From August 10 through August 21, 1998, the Quality Assessment (QA) department performed a detaiied review of the surveillance requirements of Technical Specifications (TS) 3.8.3.1. This review assessed the effectiveness of the controls and programs to ensure compliance with TS 3.8~3.1 "Containment Penetration Conductor*overcurrent Protection Devices."

TS 3.8.3.1 requires that the containment penetration conductor overcurrent protection devices be operable. TS surveillance requirement 4.8 3.1 a2 requires, in part, that at least once per 18 months 10% of each breaker type be tested to ensure that the breaker works as designed. Additionally, TS surveillance requirement 4.8.3.1.b requires, in part, that once per 60 months the circuit breakers be subjected to an inspection and preventive maintenance as recommended by the breaker manufacturer. Technical Specifications requires that with one or more of these protection devices inoperable, the device be restored to operable or have the ci~ctiit de-energized by tripping either the primary or secondary protect~ve device within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

NRC FORM 366A (4-95)

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) 05000311 YEAR I SE£LIJ~L I~ 3 OF 5 SALEM GENERATING STATION UNIT 2 98 - 013 - 00 TEXT (If more space is ~quired, use additional copies of NRC Fonn 366A) (17)

DESCRIPTION OF OCCURRENCE: (cont'd)

The QA assessment determined that a type of *low voltage breakers (TEC type) had exceeded the requirement of TS 4.8.3.1.a2 (10% being tested every 18 months). Specifically; the-TEC type breakers (6 breakers are contained in thi~ type) were identified as not having met the surveillance requirement of having been properly tested within the 18 months frequency (plus the 25% grace period) required by TS surveillance 4.8.3.1.a2. The overloads on these breakers had most recently been tested in the timeframe of September-1996. Upon identification by QA, . Operations entered ----

Technical Specification Action Statement (TSAS) 3~8.3.1 at 0940 on August 20, 1998, and exited the TSAS at 1528 on the same day, following completion of the TS surveillance.

Because of the identified missed TS surveillance by QA, a level 1 root cause team was established to *determined the root cause(s) of the missed TS surveillance. As a result of the team's investigation, one additional breaker (from a different breaker type, CF) was identified as not having been properly tested. This breaker was tested on September 3, and the results of the test_ were acccepted by Engineering on September 4, 1998.

This engineering evaluation was required in order to compensate for the difference* .in ambient temperature conditions of the trip device. The TSAS

• 3.8.3.1 was exited on September 11,- 1998, following the revision of the test procedure. Therefore, ~alem Unit 2 was operated in Modes 1 through 4, contrary to the requirements of TS 3.8.3.1, and this condition is reportable under 10CFR50.~3(a) (2) (i) (B).

CAUSE OF OCCURRENCE:

The apparent cause for these occurrences is attributed.to human error.

Inattention to detail caused the missed surveillance of the TEC type breaker. The initial creation of the recurring tasks (RTs) in the 1988-1991 timeframe should have created two separate RTs. A separate RT should have been created to track the 10% sampling. As the system was created and modified in the 1988-1991 timeframe, the system depended on human intervention (since no 18 month RT was Created) to ensure the 10% sampling wa.s performed. The human error associated with the CF type breaker is related to the failure of Planning and Engineering personnel to follow procedures. This breaker was identified as not having been included in the testing program, while the unit was in Mode 5 (a non app~icable Mode).

Failure to follow procedures resulted in the inappropriate deferral and f~ilure to test the identified breaker, when the unit entere~the applicable Mode (Mode 4).

NRC FORM 366A (4-95)

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NRC FORM'366A

============ U.S. NUCLEAR REGULATORY COMMISSION

\' (4-95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACIL1TY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE(3) 05000311 YEAR I SE~uJ:JlfL I~ 4

• OF 5 SALEM GENERATING STATION UNIT 2 98 - 013 - 00 TEXT (If more space is required, use additional copies of NRC Fonn 366A) (17)

CAUSE OF OCCURRENCE: (contn'd)

The following apparent contributing factors played *an instrumental role in the human errors; 1) an ineffective implementation of the requirements of technical Specification 4. 8. 3. 1. a2- (scheduling of a 10% sampling of each type of low voltage breaker every 18 months), 2) inadequate training and lack~f knowledge of personnel associated with the surveillance program, and~3) ineffective corrective actions from prior events.

PRIOR SIMILAR OCCURRENCES : **- *

• A review of LERs for the past two years identified:

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a)- . Two LERs relative to missed Technical Specification Surveiilances specifically associated with Containment Penetration Overcurrent Protection Devices.

- - -i. LER 311/96-007 and its . supplements dealt w+/-th eontainment Penetration Overcurrent Protection Devices not b~ing tested as required due to inadequate configuration controls, as well as hurtia"h error.

Corrective actions taken included p~ocedure changes, and drawing updates. ---.. ------- ------ ----------- * -

• ___ 2_._i.E:R:--272/97:-:-004 "Inadequate *.-surveilla-nce

• T-estin-g -of Molded case -

Circuit Breakers" identified that the instantaneous element of the protective devices was not adequat.el..y tested due to an _inadequate acceptance criterion in the procedure. Corrective actions ~aken included procedure changes.

b) Sixteen LERs related to missed Technical Specification Surveillances where the root cause was attributed to either to personnel error, procedure deficiencies, and/or management/QA deficiencies. These LERs are: for Unit 1 LER 272/96-041, 272/96-023, 272/96-017, 272/96-016, 272/96-006, 272/96-005-00, 01, 04, 05, 06, and 09, 272/96-004, 272/97-012, and for Unit 2 LER 311/96-013, 311/96-011, 311196-010, 311/96-005 311/96-003, 311/97-011, 311/97-007, and 311/97-001.

These LERs will be included in the level 1 root cause investigation~

SAFETY CONSEQUENCES AND IMPLICATIONS:

The failure to test molded case circuit breakers that are credited with primary or backup protection of electrical penetrations jeopardizes containment integrity in the event of an overcurrent situation.

INRC FORM 366A U.S. NUCLEAR RFGULATORY COMMISSION II

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(4-QS) .

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE(3) 5 OF 5 SALEM GENERATING STATION UNIT 2 98 - 013 - 00

• TEXT (If more space is required, use additional copies of NRC Fonn 366A) (17)

SAFETY CONSEQUENCES AND IMPLICATIONS: (contn'd)

For a failure*to trip coupled with a failure of the alternate protection device and high currents, heat damage and po*ssibly fire at the containment peDetration could result. Loss of penetration integrity is assumed in this instance.resulting in reduced containment integrity and the potential for release of radioactive material during normal operations or accident conditioris. However, since none of the.a{~ected penetrations were daciaged as a result of the failure to test the circuit ~reakers, and both breakers were successfully tested,_there was no comprorn.tse of containment infeg:rity. _ Therefore, this .occurrence. .did not affect the health and safety of the_p~blic.

CORRECTIVE ACTIONS

1. A level 1 root cause team was established to investigate this event, as well as other missed Technical Specification surveillances, for common issues (see Prior Similar Occurrences s*ection). ** Upon completion of this inve~tigation, this- LER report -may be supplemented in accordance with the :r:_equirements of NURE_G lP.2-2.~ __

2- One -.of the .identified TEC .type low voltage_ breakers was satisfactorily tested. Satisfactorily testing this breaker type provided compliance with TS 4. 8. 3. L a2 --(1_0% ~be.:!,p_g~ ~ested eve.r_y 18 months).

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3. The breaker identified by the root cause team (CF type) was tested on September 3, 1998, and the results of the_._tes.:t-ingwere accepted in September 4, 1998 by Engineering. Satisfactorily testing this breaker type provided compliance with TS 4 .. 8. 3 .1. a2 ( 10% being tested every 18 months).

• 4. A comparison of the MMIS database to the design engineering calculation was performed to ensure that the MMIS database contained all the required overcurrent protection devices. The comparison showed that the breakers in the_design calculation were included in the MMIS ,database.

5. Personnel involved in this event have been disciplined, as appropriate, in accordance with PSE&G policies.

6. The RTs will be revised to ensure the performance of the 10% sampling requirements.

7. A training and qualification program will be established f9r individuals

. involved in Technical Specification surveillance administration.