ML18100A975

LER 94-004-00:on 940303,late Performance of Offsite Power Availability Surveillance Discovered.Caused by Mgt/Quality Assurance Deficiency.Event Reviewed W/Personnel & Expected Action reinforced.W/940330 Ltr

ML18100A975
Person / Time
Site:	Salem
Issue date:	03/30/1994
From:	HAGAN M J, PASTVA M J Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-94-004-01, LER-94-4-1, NUDOCS 9404040102
Download: ML18100A975 (6)

Text

• . e Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038 Salem Generating Station u. s. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

Dear Sir:

SALEM GENERATING STATION LICENSE NO. DPR-75 DOCKET NO. 50-311 UNIT NO. 2 LICENSEE EVENT REPORT 94-004-00 March 30, 1994 This Licensee Event Report is being submitted pursuant to the requirements of Code of Federal Regulation 10CFR50.73(a)

(2) (i) (B)

• Issuance of this report is required within thirty (30) days of event discovery.

MJPJ:pc D,istr ibution flAfln=:i:

9404040102 940330 PDR ADOCK 05000311 S PDR The power is in your hands. Sincerely yours, General Manager -Salem Operations 95-2189 REV 7*92 NRC FORM 366 (5-92) .S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150-0104 EXPIRES 5/31 /95 LICENSEE EVENT REPORT (LEA) (See reverse for required number of digits/characters for each block) ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE INFORMATION AND RECORDS MANAGEMENT BRANCH (MNBB 7714), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555-0001, AND TO THE PAPERWORK REDUCTION PROJECT (3150-0104), OFFICE OF MANAGEMENT AND BUDGET, WASHINGTON, DC 20503. FACILITY NAME (1) DOCKET NUMBER (2) PAGE (3) Salem Generating Station -Unit 2 05000 311 1 OF 04 TITLE (4) Late Performance Of Offsite Power Avail. Surv. Due To Untimel Determination Of 2A D/G. EVENT DATE 5 LEA NUMBER 6 REPORT NUMBER 7 OTHER FACILITIES INVOLVED 8 MONTH DAY 03 03 OPERATING MODE (9) YEAR 94 1 YEAR 94 SEQUENTIAL NUMBER 004 REVISION NUMBER 00 MONTH DAY YEAR 03 30 94 FACILITY NAME FACILITY NAME DOCKET NUMBER 05000 DOCKET NUMBER 05000 THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: Check one or more 11 20.402(b) 20.405(c) 50.73(a)(2)(iv) 73.71 (b) 20.405(a)(1)(i) 50.36(c)(1)

.50.73(a)(2)(v) 73.71 (c) 20.405(a)(1

)(ii) 50.36(c)(2) 50.73(a)(2)(vii)

OTHER 20.405(a)

(1)(iii) x 50.73(a)(2)(i) 50.73(a) (2)(viii)(A) (Specify in Abstract i-.j._ _ __;_.:...:....:;..:_:

_____

below and in Text, NRC 20.405(a)(1)(iv) 50.73(a)(2)(ii) 50.73(a)(2)(viii)(B)

Form 366A) 20.405(a)(1)(v) 50.73(a)(2)(iii) 50.73(a)(2)(x)

LICENSEE CONTACT FOR THIS LEA 12 TELEPHONE NUMBER (Include Area Code) M. J. Pastva, Jr. -LER Coordinator (609) 339--5165 CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TO NPRDS CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TO NPRDS EXPECTED MONTH DAY YEAR YES SUBMISSION (If yes, complete EXPECTED SUBMISSION DATE) x DATE (15) ABSTRACT {Limit to 1400 spaces, i.e., approximately 15 single-spaced tyP.ewritten lines) . At 0500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> on 3/3/94, required Action "a.' of Technical Specification (TS) 3.8.1.1. should have been performed due to clearing and tagg,ing of A air receiver of 2A Diesel* Generator (DG) . TS 3.8.1.1 .. a requires demonstrating operability of the remaining independent alternating current circuit within one hour by performing TS 4.8.1.1.1.a and at least once per eight hours thereafter.

This event was recognized at 0900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> (same day) and TS 4.8.1.1.1.a was satisfactorily completed at 0912 hours0.0106 days <br />0.253 hours <br />0.00151 weeks <br />3.47016e-4 months <br />. This event is attributed to management deficiency due to inadequate communication when Operations personnel incorrectly interpreted that an administrative requirement, to declare a DG inoperable when one of its starting air trains are removed from service, no longer applied. Historically, similar clearing and tagging evolutions were performed without declaring the involved DG inoperable.

The basis for this practice is outlined in PSE&G's response to NRC's Notice of Violation contained in Inspection Report 50-272/93-23; 50-311/93-23, which concluded such practice does not involve a TS violation.

Expectations regarding unavailability of DG starting air train have been reinforced with all Licensed Operations personnel and the station planning department.

These expectations will remain in effect pending final disposition of PSE&G's response to the subject NRC Notice Of Violation.

NRC FORM 366 (5-92)

BLOCK NUMBER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 REQUIRED NUMBER OF DIGITS/CHARACTERS FOR EACH BLOCK NUMBER OF DIGITS/CHARACTERS TITLE UP TO 46 FACILITY NAME 8 TOTAL 3 IN ADDITION TO 05000 DOCKET NUMBER VARIES PAGE NUMBl;:R UP TO 76 TITLE 6 TOTAL 2 PER BLOCK .EVENT DATE 7TOTAL 2 FOR YEAR 3 FOR SEQUENTIAL NUMBER LEA NUMBER 2 FOR REVISION NUMBER 6 TOTAL 2 PER BLOCK REPORT DATE UP TO 18 FACILITY NAME 8 TOTAL -DOCKET NUMBER OTHER FACILITIES INVOLVED 3 IN ADDITION TO 05000 1 OPERATING MODE 3 POWER LEVEL 1 CHECK BOX THAT APPLIES REQUIREMENTS OF 10 CFR UP TO 50 FOR NAME 14 FOR TELEPHONE LICENSEE CONTACT. CAUSE VARIES 2 FOR SYSTEM 4 FOR COMPONENT EACH COMPONENT FAILURE 4 FOR MANUFACTURER

• NPRDS VARIES 1 CHECK BOX THAT APPLIES SUPPLEMENTAL REPORT EXPECTED 6 TOTAL 2 PER BLOCK EXPECTED SUBMISSION DATE LICENSEE EVENT REPORT (LER) TEXT CONTINUATION Station DOCKET NUMBER 5000311 PLANT AND SYSTEM IDENTIFICATION:

Westinghouse

-Pressurized Water Reactor LER NUMBER 94-004-00 PAGE 2 of 4 Energy Industry Identification System (EI!S) codes are identified in the text as {xx} IDENTIFICATION OF OCCURRENCE:

Late Performance Of Offsite Power Availability Surveillance Due To Untimely Determination Of 2A Diesel Generator Inoperability Event Date: 3/3/94 Report Date: 3/30/94 This report was initiated by Incident Report No.94-076. CONDITIONS PRIOR TO OCCURRENCE:

Mode 1 Reactor Power 100 % -Unit Load 1110 MWe RIPTION OF OCCURRENCE:

At 0500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> on March 3, 1994, Action "a." of Technical Specification (TS) 3.8.1.1. should have been performed due to clearing and tagging of the A air receiver of 2A Diesel Generator (DG) {VJ} which, by administrative control, requires declaring the DG inoperable.

TS 3.8.1.1.a requires demonstrating operability of the remaining independent alternating current (A.C.) circuit within one hour by performing TS Surveillance Requirement 4.8.1.1.1.a and at least once per eight hours thereafter.

This event was not recognized until 0900 (same day) and TS Surveillance Requirement 4.8.1.1.1.a was satisfactorily completed at 0912 hours0.0106 days <br />0.253 hours <br />0.00151 weeks <br />3.47016e-4 months <br />. ANALYSIS OF OCCURRENCE:

Each Salem Unit has three DGs available to supply emergency electrical power to the safety related equipment.

DG operability requires certain minimum auxiliary equipment be available.

TS 4.8.1.1.1.a imposes restrictions upon continued facility operation to ensure the initial condition assumptions of the accident analyses are met. These assumptions are based upon maintaining at least two independent sets of onsite A.C. and direct current (D.C.) power sources and associated distribution systems OPERABLE during accident conditions coincident with an assumed loss of offsite power and a single failure of one onsite A.C source.

LICENSEE EVENT REPORT (LER) TEXT CONTINUATION em Generating Station Unit 2 DOCKET NUMBER 5000311 ANALYSIS OF OCCURRENCE: (cont'd) LER NUMBER 94-004-00 PAGE 3 of 4 The starting air system of each DG consists of two independent trains with each train having a starting air receiving tank and two starting air motors. The DG is designed and qualified to start and attain rated speed on any pair of air start motors within 10 seconds of a demand signal. Operability of the trains (two of the four air start motors per DG) is currently demonstrated monthly on alternating months in accordance with surveillances S2.0P-ST.DG-0001, 0002, and 0003. At 0500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> on March 3, 1994, the A starting air receiver of 2A DG was cleared and tagged to perform maintenance on the air receiver check valve 21DA6A. Prior to this evolution, the redundant starting air train (B) starting air receiver and compressor were verified to be functioning satisfactorily.

No tagging was applied to the DG, which would have prevented it from performing its intended safety function.

Subsequently, at 0900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> (same day) it was determined that the DG should have been declared inoperable because of existing administrative controls when the A starting air receiver was removed from service. As such, the required surveillance was not completed

• until 0912 hours0.0106 days <br />0.253 hours <br />0.00151 weeks <br />3.47016e-4 months <br /> (same day). A Night Order Book (NOB) entry, dated November 5, 1993, requires declaring a DG inoperable whenever a starting air train is removed from service (rendered unavailable).

APPARENT CAUSE OF OCCURRENCE:

The cause of this occurrence is "Management/Quality Assurance Deficiency", as classified in Appendix B of NUREG-1022, and resulted from inadequate communication.

Following the submittal of PSE&G's response to NRC's Notice of Violation contained in Inspection Report 50-272/93-23; 50-311/93-23, Operations personnel incorrectly interpreted that the NOB entry of November 5, 1993 no longer applied. Historically, PSE&G has performed similar clearing and tagging of single DG starting air receivers without declaring the involved DG inoperable.

The basis for this practice is outlined in PSE&G's response to the violation, which concluded such practice does not involve a TS violation.

PREVIOUS OCCURRENCES:

As outlined in the aforementioned notice of violation, prior similar occurrences involving removing DG starting air trains without administratively declaring the DG inoperable have occurred.

PSE&G's response in regard to these occurrences is provided within its response to the notice of violation.

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• LICENSEE EVENT REPORT (LER) TEXT CONTINUATION em Generating Station Unit 2 SAFETY SIGNIFICANCE:

DOCKET NUMBER 5000311 LER NUMBER 94-004-00 PAGE 4 of 4 This event did not affect the health and safety of the public. It is reportable pursuant to the requirements of 10CFR50.73(a)

(2) (i) (B) as a condition prohibited by TS. Operability of the independent trains (two the four air start motors per DG) is demonstrated monthly on alternating months in accordance with surveillances S2.0P-ST.DG-0001, 0002, and 0003. This demonstrates the ability of each DG to start within design parameters and carry out their safety function with an unavailable starting air train. Throughout this event, 2A DG was fully capable of automatic starting and was considered inoperable due to administrative controls.

The satisfactory performance of TS 4.8.1.1.1.a verified proper alignment of the independent A.C. trains. In addition, two independent sources of offsite power were available at all times. As such, minimal consequence existed due to the late performance of the TS surveillance, since the DG was capable of automatic starting.

ECTIVE ACTION: The expected action, to declare a DG inoperable in accordance with TS 3.8.1.1 whenever a starting air train is removed from service (rendered unavailable), has been reinforced with all Licensed Operations personnel.

The station planning department has also been advised that unavailability of a DG starting air train invokes entering the TS Limiting Condition of Operation and the required surveillance must be performed.

The above described actions will remain in effect until final disposition of PSE&G's response to the subject NRC Notice Of Violation at which time they will either become a permanent requirement or will be revised accordingly.

MJPJ:pc Mtg.94-026