ML18096A357

LER 91-016-00:on 911025,two Hose Stations Inadvertently Deleted from Procedure Re Detailed Insp of TS-related Hose Stations.Caused by Inappropriate Procedural Rev.Procedure Writer & Reviewer counseled.W/911122 Ltr

ML18096A357
Person / Time
Site:	Salem
Issue date:	11/22/1991
From:	POLLACK M J, VONDRA C A Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-91-016-02, LER-91-16-2, NUDOCS 9111270002
Download: ML18096A357 (5)

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 91-016-00 November 22, 1991 Report is being submitted pursuant to the Code of Federal Regulations lOCFR This Licensee Event requirements of the 50. 73 (a} (2) (i} (B}. of discovery.

This report is required within thirty (30) days MJP:pc Distribution Sincerely yours, C. A. Vondra General Manager -Salem Operations 95-2189 (10M) 12*

NRC FORM 366 (6-89) U.S. NUCLEAR REGULATORY COMMISSION

• APPROVED OMB NO. 3150-0104 EXPIRES: 4/30/92 LICENSEE EVENT REPORT (LERI ESTIMATED BURDEN PER RESPONSE TO COMPLY WTH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE RECORDS AND REPORTS MANAGEMENT BRANCH (P-530), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555, AND TO THE PAPERWORK REDUCTION PROJECT (3150-0104), OFFICE OF MANAGEMENT AND BUDGET, WASHINGTON, DC 20503. FACILITY NAME (1) Balem Generating Station -Unit 2 TITLE 141 Missed Tech. Spec. Surv _2 Tire hoses not frequency.

EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) MONTH DAY YEAR YEAR r:u

f(

MONTH DAY YEAR inspected at the required OTHER FACILITIES INVOLVED (8) FACI LITV NAMES DOCKET NUMBER(SI THIS REPORT IS SUBMITTED PURSUANT TO THE RhOUIREMENTS OF 10 CFR §: (Chock on* or mars of th* following)

(11) OPERATING l

_________

MODE (9) 20.402(b) 60.73(ol(21(iv) 73.71 (bl

--POWER I 20.405(01(1)111 60.73(ol(2JM 73.71(cl LEVEL l I Q Q --l--.._.....,;l...;10.;..l

_"--"" ...... l..._...1---1 20.405(0)11)(11) 60.73(oJl2)(vii)

,...._

11191111=

20.405(o)(1Hilil 60.73(oJl21(viilJ(A) 366AJ 20.405(oll1J(lv) 60.73(o1(2JlviiillBI 20.4051oll1 IM 50.73loll2lliiil 60.73(oll211xl LICENSEE CONTACT FOR THIS LER (12) NAME TELEPHONE NUMBER M.J. Pollack -LER Coordinator AREA CODE COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (131 CAUSE SYSTEM COMPONENT MANUFAC* TUR ER

j:!.l .. ,l!:'!*i!!:.!.:.,!!*::l!li:*:!'!i*:!!!:,:*::!

CAUSE SYSTEM R

'i!!.:*:::*i!i*:i*i::***.::*,1,:=::*::.::11::1::1::::

COMPONENT MANUFAC* TUR ER I I I I I I I I I I I I I I .::: .. :**= .. :::1::::':.*.!::,.*1!1:::::=::':':::::::

I I I I I I I I I I I I I I SUPPLEMENTAL REPORT EXPECTED (141 MONTH DAY YEAR EXPECTED SUBMISSION DATE (151 hi NO h YES (If yos, comploto EXPECTED SUBMISSION DATE) I I ABSTRACT (Limit to 1400 spaces. i.e .* 11pproximately fiftetJn single-space typewritten JintJs) (16) On 10/25/91, a staff engineer discovered that procedure MlO-SST-023-2 "Detailed Inspection of Technical Specification Related Hose Stations", used to satisfy surveillance requirements for Technical Specification 4.7.10.4.b.

every 18 months, was incorrect.

Two (2) hose stations, 2FP229 and 2FP230, had been inadvertently deleted from Attachment 1 of the procedure when it was revised in June 1989. The surveillance was performed once, in November 1990, since it was inappropriately revised. The last successfully completed surveillance, prior to the inappropriate procedure revision, was in May 1989. The Operating Shift was informed and Action Statement 3.7.4.10 was entered. The root cause of the inappropriate procedural revision is personnel error (inattention to detail}. The procedure writer did not verify the accuracy of the revision which deleted fire hose stations 2FP229 and 2FP230 from Attachment

1. The procedure writer and procedure reviewer, who processed the procedure revision, have been counseled.

The procedure error was corrected and hose stations 2FP229 and 2FP230 were inspected as per the corrected procedure.

The Fire Protection Department will review their Technical Specification surveillance procedures revised after July 1989. The Fire Protection Department reviewed this event with their procedure writers and procedure reviewers.

Procedure, NC.NA-AP.ZZ-0032(Q}, "Preparation, Review and Approval of Procedures", will be reviewed and revised, as necessary.

NRC Form 366 (6-89) I LICENSEE EVENT REPORT (LER) TEXT CONTINUATION Salem Generating Station Unit 2 DOCKET NUMBER 5000311 PLANT AND SYSTEM IDENTIFICATION:

Westinghouse

-Pressurized Water Reactor LER .. NUMBER 91-0'16-00 PAGE 2 of 4 Energy Industry Identification System (EIIS) codes are identified in the text as {xxl IDENTIFICATION OF OCCURRENCE:

Missed Technical Specification surveillance, two (2) fire hose stations not detail inspected at the required frequency.

Discovery Date: 10/25/91 Report Date: 11/22/91 *This report was initiated by Incident Report No.91-765. CONDITIONS PRIOR TO OCCURRENCE:

Mode 1 Reactor Power 100% -Unit Load 1150 MWe DESCRIPTION OF OCCURRENCE:

In the afternoon of October 25, 1991, a Fire Protection Department staff engineer was reviewing Fire Protection Technical tion Surveillance Procedure MlO-SST-023-2 "Detailed Inspection of Technical Specification Related Hose Stations".

The procedure is performed to satisfy surveillance requirements for Technical Specification 4.7.10.4.b.

at an eighteen (18) month frequency.

The staff engineer discovered that two (2) hose stations, 2FP229 and 2FP230, had been inadvertently.

deleted from Attachment 1 of the procedure when it was revised in June 1989. The surveillance was performed once, in November 1990, since it was inappropriately revised. The last successfully completed surveillance, prior to the inappropriate procedure revision, was in May 1989. The Operating Shift was informed and they verified compensatory hoses were available and entered Action Statement 3.7.4.10 at 0915 hours0.0106 days <br />0.254 hours <br />0.00151 weeks <br />3.481575e-4 months <br /> on October 26, 1991. Technical Specification Action 3.7.10.4 states: a. "With one or more of the fire hose stations in Table 3.7-11 inoperable, route an additional equivalent capacity fire hose to the unprotected area(s) from an OPERABLE hose station within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> if the inoperable fire hose is the primary means of fire suppression; otherwise, route the additional hose within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Restore the fire hose station to OPERABLE status within 14 days or, in lieu of any other report required by LICENSEE EVENT REPORT (LER) TEXT CONTINUATION Salem Generating Station Unit 2 DESCRIPTION OF OCCURRENCE:

DOCKET NUMBER 5000311 (cont'd) LER NUMBER 91-016-00 PAGE 3 of 4 Specification 6.9.1, prepare and submit a Special Report to the Commission pursuant to Specification

6.9.2 within

the next 30 days outlining the action taken, the cause of the inoperability and plans and schedule for restoring the station to OPERABLE status. b. The provisions of Specification 3.0.3 and 3.0.4 are not applicable." The surveillance procedure was corrected and the inspection of the fire hose stations of 2FP229 and 2FP230 was completed at 1115 hours0.0129 days <br />0.31 hours <br />0.00184 weeks <br />4.242575e-4 months <br /> on October 26, 1991. The Action Statement was exited at 1124 hours0.013 days <br />0.312 hours <br />0.00186 weeks <br />4.27682e-4 months <br /> the same day. APPARENT CAUSE OF OCCURRENCE:

The root cause of the inappropriate procedural revision is personnel error (inattention to detail}. The procedure writer did not verify the accuracy of the revision which deleted fire hose stations 2FP229 and 2FP230 from Attachment

1. The procedure writer provided revision bars within the body of the procedure, but did not provide any revision bars on Attachment 1, even though it had been reformatted.

The procedure reviewer did not recognize that hose stations 2FP229 and 2FP230 had been deleted from Attachment 1 because the reviewer concentrated on the changes that had been identified with revision bars in the procedure body. This type of review is consistent with existing administrative requirements.

ANALYSIS OF OCCURRENCE:

Hose stations 2FP229 and 2FP230 have been inspected monthly per Technical Specification 4.7.10.4.a.

Operable hose stations were available in the immediate area (2FP135 & 1FP135 for elevation 64' and 2FP136 & 1FP136 for elevation 84'}. Since the hose stations were found acceptable when recently inspected per the eighteen (18) month surveillance requirement, this event did not affect the health and safety of the public. However, since Technical Specification 4.7.10.4.b.

was not complied with, this event is reportable to the Nuclear Regulatory Commission, in accordance with Code of Federal Regulations lOCFR 50.73(a} (2) (i} (B}. CORRECTIVE ACTION: The procedure writer and procedure reviewer, who processed the procedure revision, have been counseled as to the importance of performing accurate reviews of revisions to procedures.

They are no longer members of the Fire Protection Department.

LICENSEE EVENT REPORT (LER} TEXT CONTINUATION Salem Generating Station Unit 2 CORRECTIVE ACTION: (cont'd} DOCKET NUMBER 5000311 LER NUMBER. 91-016-00 PAGE 4 of 4 The procedure error was corrected and hose stations 2FP229 and 2FP230 were inspected as per the corrected procedure.

The Fire Protection Department will review their Technical cation surveillance procedures revised after July 1989, to verify that similar errors have not been made. The review will be completed by March 1992. The Fire Protection Department reviewed this event with their procedure writers and procedure reviewers and has stressed the importance of performing accurate reviews of revisions to procedures.

Personnel were instructed to pay particular importance to revisions to procedures which involve attachments, forms, or exhibits which provide listings of components, systems, or structures so that data is not inadvertently deleted, changed, etc. during the revision process. Nuclear Department Administrative Procedure, NC.NA-AP.ZZ-0032(Q), "Preparation, Review and Approval of Procedures", will be reviewed and revised, as necessary, to provide additional guidance for preparing revisions to procedures.

MJP:pc SORC Mtg.91-118 General Manager -Salem Operations