ML18102A420

LER 96-023-00:on 960822,review Identified Units Transitioned from Mode 4 to Mode 3 W/Msiv Surveillance Requirement 4.7.1.5 Not Met within Stated Surveillance Interval.Caused by Inadequate Review.Ts Surveillance Improvement Initiated

ML18102A420
Person / Time
Site:	Salem
Issue date:	09/20/1996
From:	Hassler D Public Service Enterprise Group
To:
Shared Package
ML18102A419	List: ML18102A418 ML18102A420
References
LER-96-023-01, LER-96-23-1, NUDOCS 9609270155
Download: ML18102A420 (4)

Text

NRC FOJIM 3&&

• 14-951 FACILITY IAllE 111 U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LEH) (See reverse for required numbar of digit1/char11:t11rs for 111ch block) SALEM GENERATING STATION, UNIT 1 TITU 141 APPROVED BY OllB 110. 3150.0104 EXPIRES D4/3D/H ESTlllATED 1U11DE1 PBI llDPlllSE 10 CIM'l.Y Wll1I lllS IUIDllOllY llFlllllUTIOI COwmDI llEllUEIT:

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DC 21513. DOCIET IUlllEI 121 05000272 PAGE !JI 1 of 4 Surveillance For Main Steam Isolation Valves Not Performed Prior To Entry Into Mode 3 As Required By Technical Specifications EVENT DATE 151 LER NUMBER 161 REPORT DATE 171 OTHER FACILITIES INVOLVED 181 llOITH DAY YEAI YEAI I IEQUEITW.

I IEYlllOI IUlllEI lllWEI llOITH DAY DOCIET IUlllEI FAcanYIWE SALEM UNIT 2 YEAI 05000311 08 22 96 96 023 00 09 20 96 FAcanYIAllE OPERATING N THIS REPORT IS SUBMITTED PURSUANT TD THE REQUIREMENTS OF 10 CFR I: (Checllon1armor1)

(11) MODEl91 20.22011111 20.2203(1HZ11vl X 5D.73(1H2Jlil 50.7311H2HviiiJ POWER 2D.2203(1K11 2D.22D311K311il 5D.73(1HZlliiJ 5D.7311H21W LEVEL 1101 000 20.220311HZllil 20.2203(1K311iiJ 50.73(1H2Jliii) 73.71 20.2203!1HZ11iil 20.2203(11141 5D.73(1HZJlivl 2D.22D311H211iiil 5D.3&1cH11 50.73(1H2Hvl 2D.2203(1H211ivl 50.3&1cH21 50.7311HZHviiJ LICENSEE CONTACT FOR THIS LER 1121 UllE TELEPHOIE IUl8El llodd1 Ano CMll Dennis V. Hassler, LER Coordinator 609-339-1989 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT 1131 SUPPLEMENTAL REPORT EXPECTED 1141 'YES Pf yes, complete EXPECTED SUBMISSION DATE). ABSTRACT !Limit to 1400 spaces, i.11., 11pproximat11ly 151ingla-spac11d typawritten lines) 1161 EXPECTED SUBMISSION DATE(151 MONTH DAY YEAR On August 22, 1996, a review identified that Salem Units 1 and 2 have transitioned from Mode 4 to Mode 3 with Main Steam Isolation Valve Surveillance Requirement 4.7.1.5 not met within the stated surveillance interval.

This is a violation of Technical Specification 4.0.4. The cause of this occurrence was determined to be inadequate review of the original Technical Specification 4.7.1.5 as compared to the Westinghouse Standard Technical Specification 4.7.1.5 in existence at the time. Corrective actions include submission of a License Change Request to revise the Technical Specifications.

This event is reportable in accordance with 10 CFR 50.73(a) (2) (i) (B), any condition prohibited by the plant's Technical Specifications.

9609270155 960920 PDR ADOCK 05000272 S PDR IRC FORM 316 14*95)

• llRC FORM 3&&A 14-151 U.S. llUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER) TEXT CONTINUATION FACILITY NAME (1J DOCKET NUMBER 121 05000272 SALEM GENERATING STATION, UNIT 1 TEXT Of mare sp1c1 is required, use 1ddition1I copies of NRC Form 366AJ 1171 PLANT AND SYSTEM IDENTIFICATION Westinghouse

-Pressurized Water Reactor Main Stearn/Main Stearn Isolation Valve {SB/V}* LER NUMBER 161 YEAI I IEDUEITIAL I -* IU*EI 11111m11 2 96 -023 -00 *Energy Industry Identification System (EIIS) codes and component function identifier codes appear as {SS/CC} CONDITIONS PRIOR TO OCCURRENCE PAGE 131 of At the time of identification, Salem Units 1 and 2 were shutdown and defueled.

DESCRIPTION OF OCCURRENCE 4 On August 22, 1996, a review determined that Technical Specification Surveillance Requirement 4.7.1.5, Main Steam Isolation Valve (MSIV) Full Closure Time Test, had been performed in Mode 2. The surveillance requirement is applicable in Modes 1, 2 and 3. Entry into Mode 3, without the required surveillance completed, constitutes a violation of Technical Specification 4.0.4. The Technical Specifications do not include an exception to the provisions of Technical Specification 4.0.4 to allow entry into Modes 3 and 2 from Mode 4 for the MSIVs. Technical Specifications normally require completion of the specified surveillance test within the stated periodicity to prove operability of a safety system or component before entry into a Mode or operational condition that requires the system or component to be operable and capable of performing its required function.

However, some components cannot be adequately tested in a lower Mode or operating condition.

Because of this, special provisions that allow entry into the applicable Mode (provided surveillances are promptly performed to verify operability) are inciuded in Technical Specifications.

This is accomplished by a specific exemption to Technical Specification 4.0.4 in the applicable Technical Specification.

Main Steam Isolation Valve operability testing at Salem is a specific example of the need for a provision to exempt compliance with Technical Specification 4.0.4. The steam pressure needed to properly test the valves is not available in* Mode 4, but the valves are required to be operable in Modes 1, 2 and 3. Therefore, entry into Mode 3 is necessary to test the valves. Section 10.3 of the UFSAR states that the surveillance test of the Main Stearn Isolation Valves is performed at or near 1000 psig steam pressure.

The highest steam pressure available in Mode 4 is approximately 150 psig. Past practice at Salem has been to perform the test when in Mode 2 when adequate steam is available.

At present, Technical Specification 3/4.7.1.5 remains similar to its original wording which was based on Westinghouse Standard Technical Specifications.

Salem Specification 4.7.1.5, like the Standard Technical Specification, does not provide an exemption to Specification 4.0.4. NRC FORM 366A (4-95) lllRC FORM 366A U.S. lllUCLEAR REGULATORY COMMISSIOlll FACILITY lllAME 111 LICENSEE EVENT REPORT (LER) TEXT CONTINUATION DOCKET NUMBER 121 05000272 SALEM. GENERATING STATION, UNIT 1 TEXT Pf mor111p1ce is required, use 1ddition1I copi111 of NRC Form 3&&AJ 1171 CAUSE OF OCCURRENCE LER IUMBER 161 PAGE 131 YEAI I 3 of 4 96 -023 00 The cause of this occurrence was determined to be a less than adequate review of the original Technical Specification with regard to differences from the Westinghouse Standard Technical Specifications and subsequent inadequate interpretation of Technical Specification 4.7.1.5. PRIOR' SIMILAR OCCURRENCES A review of LERs for Salem Units 1 and 2 over the last .two years identified seven LERs (272/94-008, 272/95-004, 272/95-019, 272/95-028, 311/95-006, 311/95-008, .and 272/96-016) that were a result of missed surveillances due to inadequate implementation of Technical Specification requirements.

The corrective actions were specific to the missed surveillance issues addressed in each LER. The identification of programmatic issues related to the Technical Specification requirement

• implementation resulted in the initiation of the Technical Specification Surveillance Improvement Program (TSSIP) described in LER 311/95-008. The TSSIP should ensure that Technical Specification surveillance requirements are adequately proceduralized and will also identify potentially deficient Technical Specification Limiting Conditions for Operation.

SAFETY CONSEQUENCES AND IMPLICATIONS Although entry into Modes 3 and 2 is prohibited when the MSIV testing required by Technical Specification 4.7.1.5 had not been performed, subsequent performance of MSIV testing in Mode 2 is within the currently analyzed plant operation as discussed in UFSAR Sections 10.3 and 15.4. In the occurrences described in which Specification 4.0.4 was not met, while the Unit was in Modes 2 or 3, all of the MSIVs remained closed until testing began. During testing, only one valve is opened at any time, the other three valves remaining closed, already in the safe position, thus, had* a postulated steam line break or secondary system malfunction occurred that resulted in depressurization, isolation capability would have been maintained.

A postulated failure of the tested valve in the open position would have resulted in the blowdown of only a single steam generator since the remaining three MSIVs would have been in the closed position.

Failure of a single MSIV to close is consistent with the accident assumptions presented in UFSAR Section 15.4.2. Therefore, there was no safety significance to the improper entry into Modes 3 and 2, and the health and safety of the public remained unaffected.

NRC FORM 366A (4-95)

• llRC FORM 31i&A 14-151 -. . .. . FACILITY MAME 111 LICENSEE EVENT REPORT (LEH) TEXT CONTINUATION DOCKET llUMBER 121 05000272 SALEM GENERATING STATION, UNIT 1 TEXT Pf mar111p1c11 is required, use 1dditian1I copies of NRC Form 366AI 1171 CORRECTIVE ACTION U.S. llUCLEAR REGULATORY COMMISSIOll TEAi I LER llUMBER 161 IEQUEITIAl I IU*EI 96 .. 023 -* -00 PAGE 131 4 of 4 1. A License Change Request to include an exemption to the provisions of Specification 4.0.4 in Technical Specification 4.7.1.5 will be submitted to the NRC by October 4, 1996. . *-_ . 2. Technical Specification Surveillance Improvement Program (TSSIP) has been initiated for Salem Units 1 and 2. The scope and content of the TSSIP .. program was described previously in LER 311/96-008-00.

The TSSIP review is expected to be completed by December 31, 1997. 3. This LER will be issued to the Operations Department as required reading by September 30, 1996, to further emphasize the conservative understanding and implementation of Technical Specifications.

NRC FORM 366A (4-95)