ML18106A614

LER 98-008-00:on 970814,failure to Test 21 & 22 AF 40 Valves in Closed Direction as Required by TS 4.0.5 Was Noted.Caused by Inadequate Design Mod Process.Motor Driven 21/22 AF 40 Valves Were Tested IAW Revised procedure.W/980518 Ltr

ML18106A614
Person / Time
Site:	Salem
Issue date:	05/18/1998
From:	BAKKEN A C, VILLAR E H Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-98-008-01, LER-98-8-1, LR-N980255, NUDOCS 9805270426
Download: ML18106A614 (5)

Text

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• Public: Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038-0236 Nuclear Business Unit U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

LER 311/98-008-00 MAY 18* 1998 LR-N980255 SALEM GENERATING STATION -UNIT 2 FACILITY OPERA TING LICENSE NO. DPR-75 DOCKET NO. 50-311 This Licensee Event Report entitled "Failure to Test the 21 and 22 AF 40 Valves in the Closed Direction as Required by Technical Specifications 4.0.5" is being submitted pursuant to the requirements of the Code of Federal Regulations 1OCFR50.73(a)(2)(i) (B). Attachment EHV C Distribution LER File 3.7 980S2i0426 980518 PDR ADOCK 05000311 S PDR Sincerely, A. C. Bakken Ill General Manager -Salem Operations l / i ! I I 95-2168 REV. 6/94 NRC FORM 366 U.S. EAR REGULA TORY COMMISSION

' PROVED BY OMB NO. 3150-0104 (4-95) EXPIRES 04/30/98 ESTIMATED 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 AND RECORDS MANAGEMENT BRANCH (T-6 F33J, U.S. NUCLEAR (See reverse for required number of REGULATORY COMMISSION, WASHINGTON, DC 205 5-0001, AND TO THE PAPERWORK REDUCTION PROJECT (3150-0104), OFFICE OF digits/characters for each block) MANAGEMENT AND BUDGET, WASHINGTON, DC 20503. FA'-"ILITY NAME (1) DOCKET NUMBER (2) PAGE(3) SALEM GENERATING STATION UNIT 2 05000311 1 OF 4 TITLE(4) Failure to Test the 21 and 22 AF 40 Valves in the Closed Direction as Required by Technical Specifications 4.0.5. EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (8) YEAR I FACILITY NAME DOCKET NUMBER MONTH DAY YEAR SEQUENTIAL I REVISION MONTH DAY YEAR NUMBER NUMBER SALEM 1 05000272 08 14 97 98 008 00 05 . 18 98 FACILITY NAME DOCKET NUMBER --OPERATING 3 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)

_ ..... R 0 20.2203(a)(1) 20.2203(a)(3)(i)

50. 73(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) 50.36(c)(1)

50. 73(a)(2)(v) in Abstract below or in NR 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) E. H. Villar (Station Licensing Engineer) 609 339 5456 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13) CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TONPRDS TONPRDS -. SUPPLEMENTAL REPORT EXPECTED (14) EXPECTED MONTH DAY YEAR YES x1NO SUBMISSION (If yes, complete EXPECTED SUBMISSION DATE). DATE (15) AB >TRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) (16) Based on the results of a Salem In Service Test (IST) self assessment, completed on July 31, 1997, and concerns from an IST audit conducted by Quality Assurance (QA) I PSE&G questioned whether valves 21AF40 and 22AF40 should be stroke time tested in the closed direction as well as the open direction.

Upon further review by design engineering, it was determined that the valves have a safety related function in the closed direction and they should be tested in the closed direction.

Failure to have performed this test constituted a violation of Technical Specification

4. 0. 5. The apparent cause of this condition is attributed to an inadequate design modification process. The root cause for the delay in submitting this LER is personnel error. Corrective actions taken were: the motor driven auxiliary feedwater pump recirculation valves (21/22 AF 40) were tested satisfactorily in accordance with the revised procedure, and the basis sheets in the IST program were revised and incorporated into revision 8 of the IST program. This Licensee Event Report (LER) is being made in accordance with 10 CFR 50.73 as a condition prohibited by Technical Specifications.

NRC FORM 366 (4-95)

I 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 GENERATING STATION UNIT 2 TEXT (If more space is required, use additional copies of NRC Form 366A) (17) PLANT IDENTIFICATION:

Salem Generating Station -Unit 2 Public Service Electric and Gas Company (PSE&G) Hancocks Bridge, New Jersey 08038 Westinghouse

-Pressurized Water Reactor 98 008 00

• Energy Industry Identification System (EIIS) codes and component function identifier codes appear in the text as {SS/CCC}.

Auxiliary Feedwater System (AFWS) {BA} IDENTIFICATION OF OCCURRENCE:

Date of Occurrence:

Date of Identification Report Date: August 14, 1997 April 23, 1998 May 18, 1998 CONDITIONS PRIOR TO OCCURRENCE:

Salem Unit 2 -Mode 3 DESCRIPTION OF OCCURRENCE:

Based on the results of a Salem In Service Test (IST) self-assessment, completed on July 31, 1997, and concerns from an IST audit conducted by Quality Assurance (QA), PSE&G questioned whether valves 21AF40 and 22AF40 should be stroke time tested in closed direction as well as the open direction.

The Salem self-assessment of the IST program and the QA IST audit of August 8, 1997, raised concerns about the fact that the 21/22 AF40 valves were not IST stroke tested in the closed direction.

IST review for the valves indicated that stroke time testing in the closed direction was not required due to the valves having no safety function in the closed direction.

This was based on the fact that design documentation shows the downstream orifice in the line limited maximum flow to 50 gpm. However, the IST program self-assessment showed that the results from actual performed IST procedures indicated that the AF40 valves are throttled to approximately 160 gpm (a value greater than 50 gpm) . To resolve this issued an Action Request (AR) was issued to design engineering.

Upon further review by design engineering, PSE&G determined that the valves have a safety-related function in the closed direction and they should be tested in the closed direction.

NRC FORM 366A (4-95)

NRC FORM 366A (4-95) FACILITY NAME (1) LICENSEE EVENT REPORT (LER) TEXT CONTINUATION DOCKET NUMBER (2) U.S. NUCLEAR REGULATORY COMMISSION LER NUMBER (6) PAGE (3) 05000311 YEAR I SEQUENTIAL NUMBER I REVISION NUMBER 3 OF 4 SALEM GENERATING STATION UNIT 2 98 008 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17) DESCRIPTION OF OCCURRENCE (cont'd):

Failure to have performed this test constituted a violation of Technical Specification 4.0.5. TS 4.0.5 requires that these components be tested in accordance with the requirements of Section XI of the ASME Code. This event was determined to be reportable at the time of initial discovery, however, the licensing engineer erroneously believed that this event could be submitted as a supplement to LER 272/97-001 "Inadequate IST Surveillance Of The Boron Injection Inlet valves." While preparing the supplemental report, a different licensing engineer noted that this event did not meet the requirements for a supplemental report (as stated in NUREG 1022) . CAUSE OF OCCURRENCE:

The apparent cause of this condition is attributed to an inadequate design modification process. A design change prior to the initial startup of the unit changed the from 50 gpm to 200 gpm. The design modification process failed to identify and ensure that design documentation was corrected.

This design change was implemented prior to the initial startup of the unit, prior to the existing design change process. The current design change process has checks and balances built in to avoid these types bf events. The root cause for the delay in submitting this LER is personnel error. PRIOR SIMILAR OCCURRENCES:

A review of the Salem LER database for the last two years did not reveal any similar events. LER 272/97-001 reported the failure of the IST program to include and test a number of valves utilized in the Emergency Operating Procedures.

However, as stated in the body of this LER, the root cause and circumstances of LER 272/97-001 were not similar. Therefore, the corrective actions associated with LER 272/97-001 would not have prevented this event. Additionally, the condition reported in this LER precedes LER 272/97-001 corrective actions. NRC FORM 366A (4-95)

NRC FORM 366A (4-95) U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER) TEXT CONTINUATION FACILITY NAME (1) DOCKET NUMBER (2) 05000311 YEAR I SALEM GENERATING STATION UNIT 2 98 TEXT (If more space is required, use additional copies of NRC Form 366A) (17) SAFETY CONSEQUENCES AND IMPLICATIONS:

LER NUMBER (6) SEQUENTIAL NUMBER 008 I REVISION NUMBER 00 4 The safety consequences and implications of this event were minimal. PAGE(3) OF Since the modification of the orifice, the Auxiliary Feedwater system was actuated in response to reactor trips or feedwater transients.

In all cases the auxiliary feedwater system performed its safety function as designed.

4 Additionally, the AF40 valves are normally "cycled" on pump start up in the open and closed direction.

When the pump is started, the AF40 valve opens, and when a certain flow rate is achieved, the valve receives a signal to auto close. Although the valves were not tested in the closed direction due to the erroneous information contained in the design documents; the failure of the valve to close would have been detected by operations (valve position is indicated in the control console).

CORRECTIVE ACTIONS TAKEN: 1. The 21 and 22 AF 40 valves were tested satisfactorily in accordance with the revised procedure.

The Unit 1 valves were tested in February 1998. 2. The basis sheets in the IST program were revised and incorporated into revision 8 of the IST program. 3. NUREG 1022 requirements are being reviewed with all Licensing personnel to ensure its requirements are clearly understood.*

4. Other outstanding supplemental reports were reviewed to ensure their appropriateness.

5. Personnel involved in this event were held accountable in accordance with PSE&G's procedures and policies.

NRC FORM 366A (4-95)