ML18101B179

LER 95-008-00:on 951215,Tech Spec 4.9.9 Missed Isolation Testing Discovered.Caused by Lack of Adequate Controls to Ensure All Testing Requirements Addressed.Procedure S2.IC-FT.RM--0088(Q) revised.W/960115 Ltr

ML18101B179
Person / Time
Site:	Salem
Issue date:	01/15/1996
From:	GREENLEE S, WARREN C Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-95-008-02, LER-95-8-2, LR-N96006, NUDOCS 9601190424
Download: ML18101B179 (6)

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• & Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038-0236 Nuclear Business Unit JAN 1 5 1996 LR-N96006

u. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

LER 311/95-008 SALEM GENERATING STATION -UNIT 2 FACILITY OPERATING LICENSE NO. DPR-75 DOCKET NO. 50-311 This License Event Report entitled "Technical Specification 4.9.9 Missed Isolation Initiation Testing

is being submitted pursuant to the requirements of the Code of Federal Regulations 10 CFR5 0 . 7 3 (a) ( 2 ) ( i) ( b) . Attachment SORC Mtg.96-004 JEH/tcp C Distribution LER File 3.7 190<!29 9601190424 960115 PDR ADOCK 05000311 S PDR S&reJuu_ Cla?warren

• -General Manager -Salem Operations 95-2168 REV. 6/94 Attachment A The following items represent commitments that Public Service Electric & Gas (PSE&G) made to the Nuclear Regulatory Commission (NRC) relative to this LER (311/95-008-00) . The commitments are as follows: 1. A task specific procedure for Unit 1 will be developed to address all the requirements of Technical Specification 4.9.9. This will be completed prior to core alterations on Unit 1. 2. A Technical Specification Surveillance Improvement Project (TSSIP) has been initiated for Salem station. As part of the TSSIP, a review will be performed to ensure that each Technical Specification surveillance requirement is adequately proceduralized.

The review will be completed in two stages. The first stage will involve verification that each Technical Specification surveillance requirement has an associated procedure which is listed in the Technical Specification matrix. These reviews will be prioritized such that Mode change requirements are verified prior to the applicable Mode change. Administrative processes will also be revised, as necessary, to ensure adequate controls are established for the revision of Technical Specification surveillance procedures.

The first stage of the TSSIP will be complete prior to unit restart. The second stage of the TSSIP will, with exceptions, involve validation of the technical accuracy of the Technical Specification surveillance procedures.

The exceptions will include inservice testing and inspection procedures, snubber inspection procedures and any procedures that will change significantly when Improved Technical Specifications are implemented.

The second stage of the TSSIP is expected to be completed during 1997.

.. NRCFORM366 U.S. NUCLEAR REGULATORY COMMISSION

• APPROVED BY OMB NO. 3150-0104 (4-96) EXPIRES 04130198 EmMATED BURDEN PER RESPONSE TO COMPLY WITH THIS MANDATORY INFORMATION COLLECTION REQUEST: 50.0 HRS. -LICENSEE EVENT REPORT (LER) REPORTED LESSONS LEARNED ARE INCORPORATED INTO THE LICENSING PROCESS AND FED BACK TO INDUSTRY.

FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE INFORMATION (See reverse for required number of AND RECORDS MANAGEMENT BRANCH REGULATORY COMMISSION, WASHINGTON, DC , AND TO digits/characters for each block) THE PAPERWORK REDUCTION PROJECT OFFICE OF MANAGEMENT AND BUDGET, WASHINGTON, 20503. . FACILITY NAllE (1) DOCKET NUllBER (2) PAGE(3) SALEM GENERATING STATION -UNIT 2 05000311 .. 1 OF4 TITLE(4) Technical Specification 4.9.9 Missed Isolation Testing EVENT DATE (5) LEA NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (8) YEAR I I REVISION FACILITY NAME DO.CKET NUMBER MONTH DAY YEAR SEQUENTIAL MONTH DAY YEAR NUMBER NUMBER 05000 12 15 95 95 008 00 01 15 96 FACILITY NAME DOCKET NUMBER --05000 OPERATING 6 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 0 20.2203(a)(1) 20.2203(a)(3)(i)

50. 1s(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. 73(a)(2)(v)

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 ArH Code) .Scot Greenlee, Operations Support Technical Manager 609-339-3500 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13) CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE I CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE

• TONPRDS TONPRDS SUPPLEMENTAL REPORT EXPECTED (14) EXPECTED MONTH DAY YEAR IYES XINO SUBMISSION (If yes, complete EXPECTED SUBMISSION DATE). DATE (15) ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) (16) On December 15, 1995, a review identified that the requirements of Technical Specification 4.9.9 were never fully proceduralized at Unit 2. Specifically, the surveillance procedure that has been used to implement Technical Specification 4.9.9 did not direct testing of the Containment Purge and Pressure-Vacuum Relief manual initiation function.

Thus, with the exception of the current refueling outage, it is likely that the Unit 2 Containment Purge and Pressure-Vacuum Relief manual initiation function was never tested prior to or during core alterations.

The most recent period of non-compliance was during the last core reload in late November through early December 1994. A similar issue of non-compliance did not exist at Unit 1. The cause of this occurrence was a lack of adequate controls for the development and revision of Technical Specification surveillance procedures.

Corrective actions will verify the adequacy of Technical Specification surveillance procedures and will ensure that adequate controls are in place to maintain the adequacy of the procedures.

This event is in accordance with 10 CFR 73 (a) (2) (i) (B) I any condition prohibited by the plant's Technical Specifications NRC FORM 388 (4-95)

NRC FORM 366A (4-95) U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER) TEXT CONTINUATION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) 05000311 YEAR I I == SALEM GENERATING STATION -UNIT 2 95 -008 -00 TEXT (If more space i* required, ulle additional copies of NRC Form 366A) (17) PLANT AND SYSTEM IDENTIFICATION

-Westinghouse

-Pressurized Water Reactor Containment Purge and Pressure-Vacuum Relief {BF/-}* PAGE (3) 2 OF 4 *Energy Industry Identification System (EIIS) codes and component function identifier codes appear in the text as {SS/CC } IDENTIFICATION OF OCCURRENCE Discovery Date: December 15, 1995 Event Dates: The most recent period of non-compliance was during the las*t core reload in late November through early December 1994. Prior to November 1994, it is that the same event occurred on each entry into core alterations and every seven days during core alterations since plant startup. CONDITIONS PRIOR TO OCCURRENCE The plant would have been in Mode 6 or defueled prior to each' event. There were no structures, components, or systems that were inoperable at the start of each event that contributed to the event. DESCRIPTION OF OCCURRENCE On December 8, 1995, Unit 2 operators were making preparations for core alterations.

A reactor operator was reviewing the Technical Specifications and identified a Unit 2 surveillance procedure that did not adequately address one of the tests required prior to core alterations.

Specifically, Technical Specification 4.9.9 states, Containment Purge and Vacuum Relief isolation system shall be demonstrated OPERABLE within 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to the start of and at least once per 7 days during CORE ALTERATIONS by verifying that Containment Purge and Pressure-Vacuum Relief isolation occurs on manual initiation and on a high radiation test signal from each of the containment radiation monitoring instrumentation

• channels." The surveillance procedure that has been used to implement Technical Specification 4.9.9 did not direct testing of the Containment Purge and Pressure-Vacuum Relief manual initiation function.

Additional testing was performed on December 8 that demonstrated the operability of the Unit 2 Containment Purge and Pressure-Vacuum Relief manual isolation function.

Core alterations subsequently commenced with all required tests complete.

NRC FORM 366A (4-95)

-NRC FORM 366A . (4-96) -U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER) TEXT CONTINUATION FACILITY NAME (1) DOCKET NUMBER (2) _ 05000311 SALEM GENERATING STATION -UNIT 2 TEXT (If more space is required, use additional copies of NRC Form 366A) (17) DESCRIPTION OF OCCURRENCE

-(cont'd) LER NUMBER 6) YEAR I SEQUENTIAL NUMBER REVISION NUMBER 95 -008 -00 P_AGE (3) 3 OF 4 A Containment Purge and Pressure-Vacuum Relief surveillance procedure history review for both units was performed.

It revealed that testing of the manual initiation function had never been proceduralized at Unit 2. Thus, with the exception of the current refueling outage, the Unit 2 Containment Purge and Pressure-Vacuum Relief manual initiation function most likely was never tested prior to or during core alterations.

This noncompliance issue wa_"s identified on December 15, 1995. The most recent period of non-compliance was during the previous refueling outage, which occurred in late November through early December, 1994. The Unit 1 procedure history review further revealed that only the most recent revision of the pre-core alterations Containment Purge and Pressure-Vacuum Relief surveillance procedures, Containment or Vent Air Particulate Radiation Monitor" and "lrl2a Containment or Vent Gas Effluent Process Radiation Monitor", did not contain manual initiation testing requirements.

These particular procedure revisions were never used. CAUSE OF OCCURRENCE The cause of this occurrence was that the program which implemented Technical Specification test requirements in the late l970's did not have adequate controls to ensure that all testing requirements were properly addressed.

In addition, the current programs do not have sufficient controls to identify similar existing deficiencies, or to prevent removal of steps from-procedures which are required to comply with existing Technical Specifications.

PRIOR SIMILAR OCCURRENCES Though there have been six previous missed surveillances over the last six years, a review of LERs for Salem Units 1 & 2 identified one LER related to missed surveillances due to procedural deficiencies during the last two years. This is: LER 272/94-008 Channel Ftinctional Testing of Position Indication For Power Operated Relief Valves Missed On Both Units" identified an occurrence where a procedure was revised in response to Generic Letter 90-06 without a revision to Technical Specifications which resulted in missed surveillance testing of Power Operated Relief Valves while in modes 1 & 2. NRC FORM 366A (4-95)

.Q.... ..... .. NRC FORM 368A . U.S. NUCLEAR REGULATORY COMMISSION i (4-95) LICENSEE EVENT REPORT (LER) . TEXT CONTINUATION.

FACILITY NAME (1) DOCKET NUMBER (2) 05000311 SALEM GENERATING STATION -UNIT 2 TEXT (If more space is required, use additional copies of NRC Form 366A) (17) SAFETY SIGNIFICANCE LER NUMBER 6) YEAR I SEQUENTIAL NUMBER REVISION NUMBER 95 -008 -00 PAGE (3) 4 OF 4 The safety significance for this incident is considered minimal since isolation bf the Containment Purge and Pressure-Vacuum Relief valves on a simulated high radiation signal is demonstrated as required by Technical Specification 4.9.9. The individual valves are routinely manipulated while in.Modes 5 and 6, which demonstrates proper manual circuit operation.

In adqition, Containment Purge and Pressure-Vacuum Relief isolation on the Phase A and Phase B manual isolation signals are also demonstrated to occur as required by Technical Specification 4.6.3.2.d on an 18 month CORRECTIVE ACTIONS The immediate corrective action taken*was to verify the ability to manually close of the Containment Purge and Pressure-Vacuum Relief isolation valves from the Control Room. The task specific procedure for Unit 2, Procedure "High Radiation Signal and Manual Initiation for Containment Isolation", was revised to address the requirements of Technical Specification 4.9.9. This procedure is now approved for use. A task specific procedure for Unit 1 will be developed to address all the requirements of Technical Specification 4.9.9. This will be completed pribr to core alterations on Unit 1.-A Technical Specification Surveillance Improvement Project (TSSIP) has been initiated for Salem station. As part of the TSSIP, a review will be performed to ensure that each Technical Specification surveillance requirement is adequately proceduralized.

The review will be completed in two stages. The first stage will involve verification that each Technical Specification surveillance requirement has an associated procedure which is listed in the Technical Specifications matrix. These reviews will be prioritized such that Mode change requirements are verified prior to the applicable Mode Administrative processes will also be. revised, as necessary, to ensure adequate controls are established for the revision of Technical Specification surveillance procedures.

The first stage of the TSSIP will be complete prior to unit restart. The second stage of the TSSIP will, with exceptions, involve validation of the technical accuracy of the Technical Specification surveillance procedures.

The exceptions will include inservice testing and inspection procedures, snubber inspection procedures and any procedures that will change significantly when Improved Technical Specifications are implemented.

The second stage of the TSSIP is expected to be completed during 1997. NRC FORM 366A (4-95)