ML18101A907

LER 95-018-00:on 950720,improper Range Gauges Used for Ist.Caused by Case Code Classification E, Mgt/Qa. Stop Work Order Has Been Issued by QA for All IST Surveillance testing.W/950818 Ltr

ML18101A907
Person / Time
Site:	Salem
Issue date:	08/18/1995
From:	Parris L, Warren C Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-95-018, LER-95-18, NUDOCS 9508240176
Download: ML18101A907 (6)

Text

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• Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038-0236 Nuclear Business Unit August 18, 1995 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Attn.: Document Control Desk SALEM GENERATING STATION LICENSE NO. DPR-70 DOCKET NO. 50-272 UNIT NO. 1 LICENSEE EVENT REPORT NO. 95-018-0 This Licensee Event Report entitled "Improper Range Gauges Used for Inservice Testing," is being submitted pursuant to the requirements of the Code of Federal Regulations 10CFR50.73(a)(2)(i). Attachment A contains those commitments which are currently outstanding related to this issue.

Sincerely, dac; f. ~.ffe--

Clay C. Warren General Manager -

Salem Operations Attachment A SORC Mtg.95-091 MNA/tcp C Distribution LERFile

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• t::. \\ i.:: :-.. i..:"':\.:.'. 9508240176 950818 PDR ADOCK 05000272 1u?*ri S PDR JI 95-2168 REV. 6/94

ATTACHMENT A

• PSE&G Commitments for LER 272/95-018-0 The following items represent PSE&G's commitments made to the Nuclear Regulatory Commission related to LER 272/95-018-0. The commitments are as follows:

One Time Actions

1. A revision to the RHR (Residual Heat Removal) and BAT (Boric Acid Transfer) pump testing procedures will be completed to specify the range and accuracy of portable test instruments that will be used for Technical Specification 4.0.5 pump testing. The range and accuracy will be specified to ensure that the instruments meet the requirements of ASME Section XI.

2. An assessment of the entire IST program and implementing procedures is underway to identify all aspects of the program which may not be in compliance with ASME Section XI requirements. This assessment is expected to conclude by October 31, 199 5.

3. Provide a supplement to this LER on or before November 17, 1995.

NRC FORM 366 (4-95)

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

• APPROVED BY OMB NO. 3150-0104 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 COMMENTS REGARDING BURDEN ESTIMATE TO THE INFORMATION ANO RECORDS MANAGEMENT BRANCH (T-6 F33), U.S. NUCLEAR (See reverse for required number of REGULATORY COMMISSION, WASHINGTON, DC 20555--0001, ANO TO THE PAPERWORK REDUCTION PROJECT (3150-0104), OFFICE OF digits/characters for each block) MANAGEMENT ANO BUDGET, WASHINGTON, DC 20503.

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

SALEM, UNIT 1 05000272 1 OF4 TITLE (4)

IMPROPER RANGE GAUGES USED FOR INSERVICE TESTING 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 FACILITY NAME SALEM, UNIT 2 DOCKET NUMBER 05000311 07 20 95 95 -- 018 -- 0 08 18 95 FACILITY NAME *DOCKET NUMBER 05000 TING THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check one or more) (11)

) 5 20.2201(b) 20.2203(a)(2)(v) x 50. 73(a)(2)(i) 50. 73(a)(2)(viii) 20.2203(a)(1) 20.2203(a)(3)(i) 50. 73(a)(2)(ii) 50. 73(a)(2)(x)

) 000 20.2203(a)(2)(i) 20.2203(a)(3)(ii) 50. 73(a)(2)(iii) 73.71

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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)

LEE A. PARRIS, IST ENGINEER (609) 339-2024 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TONPROS TO NPROS X 'YES SUPPLEMENTAL REPORT EXPECTED (14)

(If yes, complete EXPECTED SUBMISSION DATE).

I INO EXPECTED SUBMISSION DATE (15)

MONTH 11 DAY 17 YEAR 95 ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) (16)

On July 20, 1995, while conducting a routine biennial Quality Assurance (QA) audit of the Salem lnservice Testing (IST) Program, a reportable programmatic deficiency was identified concerning the failure to use the proper range gauges for pump testing. This deficiency constitutes a violation of Technical Specification 4.0.5 in that the testing of certain components was not performed in accordance with ASME Section XI requirements. The deficiency involves the failure to use the proper gauges for the testing of 11, 12, 13, 21,22, & 23 Component Cooling (CC) pumps, 12 & 22 Boric Acid Transfer (BAT) pumps and 12 Residual Heat Removal (RHR) pump. Review of test data did not reveal any operability concern with these pumps based on the gauges used for the testing. The installed gauges were reviewed against the guidance provided in NUREG-1482, "Guidelines for lnservice Testing at Nuclear Power Plants." The gauges used meet the intent of the code as described in NUREG-1482 and the data collected using these gauges is considered to be acceptable for use in determining the operational condition of the pumps. The most recent test data indicates that the pumps are performing in the acceptable range allowed by the IST program and are therefore considered operable. Nonetheless, this condition constitutes a violation of Technical Specification 4.0.5 since specific prior approval (code relief) from the NRC is required to use gauges outside the range of three times the reference value. Procedure changes are being implemented to require that the proper range gauges are used for future testing. Evaluation of and modifications to the IST program are continuing in order to address this and other programmatic weaknesses.

NRC FORM 366 (4-95)

NRC FORM 366A (4-95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION

• U.S. NUCLEAR REGULATORY COMMISSION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3)

SALEM, UNIT 1 05000272 YEAR I SEQUENTIAL NUMBER IREVISION NUMBER 2 OF 4 95 - 018 0 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

Plant and System Identification:

Westinghouse - Pressurized Water Reactor Energy Industry Identification System (EllS) codes and component function identifier codes appear in the text as {XX/XX}.

Identification of Occurrence During the biennial Quality Assurance (QA) audit, lnservice Testing Program deficiencies were identified which constitute violations of Technical Specification 4.0.5.

Event Date: July 20, 1995 Report Date: August 18, 1995 This report was initiated by Incident Report No. 95-1162 Conditions Prior to Occurrence:

Both Units were in a self-imposed extended shutdown.

Mode: 5 Reactor Power: % Unit Load: MWe Description of Occurrence:

On July 20, 1995, while conducting a routine biennial Quality Assurance (QA) audit of the Salem lnservice Testing (IST) Program, a reportable programmatic deficiency was identified concerning the failure to use the proper range gauges for pump testing. This deficiencies constitutes a violation of Technical Specification 4.0.5 in that the testing of certain components was not performed in accordance with ASME Section XI requirements.

The deficiency involves the failure to use the proper range gauges for the testing of 11, 12, 13, 21,22, &

23 Component Cooling (CC) {CC/P} pumps, 12 & 22 Boric Acid Transfer (BAT) {CB/P} pumps and 12 Residual Heat Removal (RHR) {BP/P} pump. ASME Section XI, subsection IWP 4120 requires that, "The full scale range of each instrument be three times the reference value or less." The IST audit identified the following gauges (used for testing in accordance with Technical Specification section 4.0.5) as exceeding three times the reference value:

(1) the suction gauges for 11, 12, 13, 21, 22, and 23 Component Cooling (CC) pump gauges, (2) the suction gauges for 12 and 22 Boric Acid Transfer (BAT) pumps, and (3) the suction and discharge pressure gauges for 12 Residual Heat Removal (RHR) pump (for Mode 5 & 6 testing).

NRG FORM 366A (4-95)

1 NRC FORM 366A (4-95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION

• U.S. NUCLEAR REGULATORY COMMISSION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3)

SALEM, UNIT 1 05000272 YEAR I SEQUENTIAL NUMBER IREVISION NUMBER 3 OF 4 95 - 018 - 0 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

Analysis of Occurrence The installed gauges (used for testing in accordance with Technical Specification section 4.0.5) were reviewed against the guidance provided specified in NUREG-1482, "Guidelines for lnservice Testing at Nuclear Power Plants." These gauges meet the intent of the ASME Code as described in NUREG-1482 with respect to accuracy of the gages. However, the gages did not meet the requirements of the ASME Code for the range (scale). The data collected using these instruments is considered to be acceptable for use in determining the operational condition of the pumps. The combined effects of range and accuracy for these gauges was determined to yield an instrument reading at least equivalent to the readings achieved from instruments that meet ASME Code requirements. The most recent test data indicates that the pumps are performing in the acceptable range allowed by the IST program and are therefore considered operable.

However, this condition still constitutes a violation of Technical Specification 4.0.5, since specific prior approval (code relief) from the NRC is required to use gauges outside the range of three times the reference value.

Apparent Cause of Occurrence The cause code classification "E", "Management/Quality Assurance" (per NU REG 1022) is attributed to this event. As discussed below, this issue was previously identified, but, as a result of inadequate corrective actions, the deficiencies were not corrected. It appears that there was a breakdown in the IST Program implementation.

Prior Similar Occurrence Non-compliance's with ASME Section XI instrument range requirements were initially identified during a IST self-assessment in January 1995. The deficiencies were documented in Incident Report 95-052. As part of the evaluation for Incident Report 95-052, an operability determination was performed which documented that the affected pumps remained operable. The combined effects of range and accuracy for these gauges was determined to yield an instrument reading at least equivalent to the readings achieved from instruments that meet ASME Code requirements. The root cause evaluation is considered inadequate since it failed to identify that the use of these incorrect gauges is not permitted without specific prior approval (code relief) from the NRC. The recommended corrective actions included revising the IST procedures to require the use portable gauges in the correct range. These corrective actions had not been implemented at the time of discovery during the QA audit of the IST program.

Safety Significance This condition is reportable pursuant to 10CFR50.73(a)(2)(i)(B) as a violation of Technical Specification 4.0.5 due to a failure to follow ASME Section XI regarding the testing of ASME Code Class 1, 2 and 3

• components. Based on our evaluation, there were no industrial safety or nuclear safety issues associated with this event. The deficiencies noted did not result in a failure to identify degradation of the affected components nor were any components identified which would have failed to perform their intended safety function.

NRG FORM 366A (4-95)

• NRC FORM 366A (4-95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION

• U.S. NUCLEAR REGULATORY COMMISSION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE(3)

SALEM, UNIT 1 05000272 YEAR I SEQUENTIAL NUMBER IREVISION NUMBER 4 OF 4 95 - 018 0 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

Corrective Actions A Stop Work Order has been issued by QA for all IST surveillance testing. The stop work order specifies that no testing shall be conducted without prior review and approval by the IST engineer. This action is being taken to ensure that all test specific requirements are reviewed prior to performing any new testing.

All instrumentation necessary for the testing of pumps needed in Modes 5 and 6 have been reviewed for their impact on surveillance test results. Investigation into all other instrumentation used for ASME Section XI testing is ongoing. Any additional ASME Section XI deficiencies that are identified will be included in supplements to this LER.

A revision to the CC pump testing procedures has been completed to specify the range and accuracy of portable test instruments that will be used for Technical Specification 4.0.5 pump testing. The range and accuracy specified ensures that the instruments meet the requirements of ASME Section XI.

A revision to the RHR and BAT pump testing procedures will be completed to specify the range and accuracy of portable test instruments that will be used for Technical Specification 4.0.5 pump testing.

The range and accuracy will be specified to ensure that the instruments meet the requirements of ASME Section XI. In the interim, the Stop Work Order (discussed above) combined with specific guidance added to existing RHR and BAT pump testing work orders (specifying instrument requirements) will ensure that ASME Section XI requirements will be met for the future testing of the RHR and BAT pumps until the procedure changes are completed.

An assessment of the entire IST program and implementing procedures is underway to identify all aspects of the program which may not be in compliance with ASME Section XI requirements. This assessment is expected to conclude by October 31, 1995. A complete upgrade of the program will be completed prior to the restart of Salem Unit 1.

Based on previously identified deficiencies with inadequate corrective actions the following actions have been taken or are underway:

A new corrective action department was established providing heightened management focus on the corrective action process and establishing daily (weekday) management review of identified conditions adverse to quality.

NC.NA-AP.ZZ-0006(0), "Corrective Action Program," has been revised to specifically define a hierarchy of event significance levels with corresponding required levels of cause investigation.

The revision also simplified and centralized the method used to enter, track and process conditions adverse to quality.

Established a corrective action review board to review the root cause determination and corrective actions for all significance level I (highest level of significance) condition reports (reports of conditions adverse to quality).

NRC FORM 366A (4-95)