ML18106A216

LER 97-013-00:on 970702,determined That EDG Should Have Been Declared Inoperable W/Test Instrumentation Connected.Caused by Personnel Error.Performed Satisfactory follow-up Test, Removed Equipment & Signed Off procedure.W/971219 Ltr

ML18106A216
Person / Time
Site:	Salem
Issue date:	12/19/1997
From:	Bakken A, Enrique Villar Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-97-013-02, LER-97-13-2, LR-N970805, NUDOCS 9801020108
Download: ML18106A216 (7)

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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 LER 272/97-013-00 DEC 19 1997 LR-N970805 SALEM GENERATING STATION -UNIT 1 FACILITY OPERATING LICENSE NO. DPR-70 DOCKET NO. 50-272 Gentlemen:

This Licensee Event Report entitled "Failure to Meet Technical Specification 3.8.1.1 Action b" is being submitted pursuant to the requirements of the Code of Federal Regulations 1OCFR50.73(a)(2)(i)(B).

Attachment EHV/tcp C Distribution LER File 3.7 9801020108 971219. PDR ADOCK 05000272 .* S PDR Sincerely, / /J A. C. Bakken Ill General Manager -Salem Operations I llllll lllll lllll llllll lllll llll llll llll The power is in your hands. *882FA2* 95-2168 REV. 6/94

" NRC FORM 366 (4-95) U.S. NUCLE EGULATORY .COMMISSION APP ED BY'OMB NO. 3150-0104 EXPIRES 04/30/98 LICENSEE EVENT REPORT (LER) (See reverse for required number of digits/characters for each block) ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS MANDATORY INFORMATION COLLECTION REQUEST: 50.0 HRS. 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 F33), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC AND TO THE PAPERWORK REDUCTION PROJECT OFFICE OF MANAGEMENT AND BUDGET, WASHINGTON, DC 20503. FACILITY NAllE (1) DOCKET NUllBER (2) PAGE (3) SALEM GENERATING STATION UNIT 1 05000272 1 of6 TITLE (4) FAILURE TO MEET TECHNICAL SPECIFICATION 3.8.1.1 ACTION B EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER.FACILITIES INVOLVED (8) FACILITY NAME DOCKET NUMBER MONTH DAY YEAR SEQUENTIAL MONTH DAY YEAR YEAR I NUMBER I REVISION NUMBER Salem Generating Station Unit 2 05000311 07 02 97 97 013 00 12 19 97 FACILITY NAME DOCKET NUMBER -05000 OPERATING 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 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 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) 11---C_A_U_S_E----lf---SY-S-TE-M-+-C-O_M_P_O_NE-NT-+-M-AN_U_F-AC_T_U_R-ER

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SUPPLEMENTAL REPORT EXPECTED (14) I YES * (If yes, complete EXPECTED SUBMISSION DATE). x1NO EXPECTED SUBMISSION DATE (15) ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) (16) MONTH DAY YEAR On July 2, 1997, the 2A Emergency Diesel Generator (EDG) was tested in accordance with surveillance test procedure, S2.0P-ST.DG-0001, 2A Diesel Generator Surveillance Test. The test was completed satisfactorily, and the EDG was declared operable at 0545. However, the test equipment was intentionally left in place to support additional EDG testing scheduled for later that day. The second test did not occur for approximately 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> later, and during this period the 2A EDG was thought to be in an Operable status. On October, 2, 1997, an engineering evaluation determined that the EDG should have been declared inoperable with the test instrumentation connected.

The for this occurrence is attributed to personnel error. Corrective actions taken included; appropriate disciplinary action was taken with involved personnel, procedures were changed, the test equipment was removed. The failure to perform this surveillance is reportable in accordance with 1OCFR50. 7 3 (a) ( 2) ( i) ( B) . NRC FORM 366 (4-95)

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (4-95) FACILITY NAME (1) LICENSEE EVENT REPORT (LER) TEXT CONTINUATION DOCKET NUMBER (2) LER NUMBER (6) PAGE (3) 05000272 YEAR I SEQUENTIAL I REVISION NUMBER NUMBER 2 OF 6 SALEM GENERATING STATION UNIT 1 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 Hancocks Bridge, New Jersey 08038 Westinghouse

-Pressurized Water Reactor 2 A Emergency Diesel Generator

{EDG) {EK}* 97 -013 00

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

IDENTIFICATION OF OCCURRENCE:

Failure to Comply with Technical Specification 3.8.1.1 Action B. Date of Occurrence:

July 2, 1997 Date of Identification:

November 30, 1997 Report Date: December 19, 1997 CONDITIONS PRIOR TO OCCURRENCE:

Salem Unit 1 -Defueled Salem Unit 2 -Mode 4 DESCRIPTION OF OCCURRENCE:

Technical Specification 3.8.1.1 states in part: "3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. Two independent A.C. circuits between the offsite transmission network and the onsite Class lE distribution system {vital bus system), and b. Three separate and independent diesel generators with: NRC FORM 366A (4-95)

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NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (4-95) FACILITY NAME (1) LICENSEE EVENT REPORT (LER) TEXT CONTINUATION DOCKET NUMBER (2) LER NUMBER (6) 05000272 YEAR I SEQUENTIAL I REVISION NUMBER NUMBER SALEM GENERATING STATION UNIT 1 97 -013 00 TEXT (If more space is-required, use additional copies of NRC Form 366A) (17) DESCRIPTION OF OCCURRENCE: (CONT'D) PAGE (3) 3 OF 6. 1. Separate day tanks containing a minimum volume of 130 .gallons of fuel, and 2. A common fuel storage system consisting of two storage tanks, each containing a minimum volume of 23,000 gallons of fuel, and two fuel transfer pumps. APPLICABILITY:

MODES 1, 2, 3 and 4. ACTION: b. With one diesel generator of the above required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the independent A.C. circuits by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter

.... " On July 2, 1997, the 2A Emergency Diesel Generator (EDG) was tested in accordance with surveillance test procedure, S2.0P-ST.DG-0001, 2A Diesel Generator Surveillance Test. The test was completed satisfactorily, and the EDG was declared operable at 0545. However, in completing the restoration portion of the procedure, the test equipment was intentionally left in place to support additional EDG testing scheduled for later that day. The procedure step that directed removal of the test equipment was marked as not applicable.

The second test did not occur for approximately 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> later on July 2, and during this period the 2A EDG was thought to be in an Operable status. Leaving the electrical test equipment unattended and installed in the 2A EDG control cabinet for this extended period of time was a condition that had not been previously evaluated.

Engineering evaluated this condition relative to three concerns;

1) the seismic adequacy of the affected cabinet with its door open (the cabinet door contains protective door mounted relays), 2) seismic adequacy of test equipment and cart, and 3) the actual test equipment electrical connection.

1. Relative to the seismic adequacy of the door mounted relays, the evaluation determined these relays would not be actuated during a seismic event with the door in the open position.

Although, these relays were seismically qualified with the doors in the closed position, based on engineering judgment and the limited motion of the door in any direction, the relays would not actuate during a seismic event with the door open. This evaluation was completed on August 29, 1997. NRC FORM 366A (4-95)

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (4-95) FACILITY NAME (1) LICENSEE EVENT REPORT (LER) TEXT CONTINUATION DOCKET NUMBER (2) LER NUMBER (6) PAGE (3) 05000272 YEAR I SEQUENTIAL I REVISION NUMBER NUMBER 4 OF 6

• SALEM GENERATING STATION UNIT 1 97 -013 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17) DESCRIPTION OF OCCURRENCE: (CONT'D) ** 2. Relative to the seismic adequacy of the test equipment and cart, the seismic evaluation determined that the test equipment would remain on the cart during a seismic event and the cart would remain upright and not move more than six inches. 3. Relative to the actual test instrumentation connection, a lOCFRS0.59 evaluated the connection of portable electrical test equipment to the EDG's potential transformer circuit (used for EDG control -

speed reference and KWS turbo boost controller) , and the Engine Start/Turbo Boost ON contact in the 125VDC circuit (used for triggering the recorder on an EDG start) . This evaluation, which was completed on October 2, 1997, indicated that without proper isolation of the electrical contacts, the EDG should have been declared inoperable.

Therefore, the 2A EDG should have been declared inoperable on July 2, 1997, and in accordance with Technical Specifications 3.8.1.1 Action b, surveillance requirement 4.8.1.1.1.a should have been performed within one hour. The failure to perform this surveillance is reportable in accordance with 10CFR50.73(a)

(2) (i) (B). Less than adequate communication between Licensing, Operations, and Engineering resulted in the information timeline presented above not being known until November 30, 1997, when the reportability determination was made. CAUSE OF OCCURRENCE:

The reason for this occurrence is attributed to personnel error. In completing the restoration portion of the procedure, the test equipment was intentionally left in place to support additional EDG testing scheduled for later that day. The procedure step that directed removal of the test equipment was marked as not applicable.

Leaving the electrical test equipment unattended and installed (and considering the EDG operable) for this extended period of time was a condition that had not been previously evaluated and changed the intent of the procedure and violated the Technical NRC FORM 366A (4-95)

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NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (4-95) FACILITY NAME (1) LICENSEE EVENT REPORT (LER) TEXT CONTINUATION DOCKET NUMBER (2) LER NUMBER (6) 05000272 YEAR I SEQUENTIAL I REVISION NUMBER NUMBER SALEM GENERATING STATION UNIT 1 97 -013 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17) PRIOR SIMILAR OCCURRENCES; PAGE(3) 5 OF 6

• A review of the LER database did not show any previous similar occurrence associated with test equipment.

A number of LER relative to failure to comply with Technical Specifications were identified*

for the past two years. A review of LERs for Salem Units 1 and 2 issued in the last two years identified one LERs (272/94-008, 272/95-004, 272/95-019, 272/95-013, 272/95-024, 272/95-028, 272/96-003, 272/96-004, 272/96-006, 272/96-008, 272/96-016, 272/96-023, 272/96-024, 311/94-012, 311/95-006, 311/95-008, 311/96-003, 311/96-005, 311/96-007, 311/96-010 and 311/96-011) that were a result of missed surveillances due to inadequate implementation of Technical Specification requirements.

The identification of these programmatic issues resulted in the initiation of the Technical Specification Surveillance Improvement Program (TSSIP) described in LER 311/95-008.

SAFETY CQNSEOQENCES AND IMPLICATIONS The safety consequences and implications of this event were minimal. The Operability of the AC (including the EDGs) ensures that sufficient power is available to supply the safety related equipment required for safe shutdown of the facility, and to mitigate accidents within the facility.

Although, the 2A EDG should have been considered inoperable, in accordance with the Technical Specifications requirements, the 2A EDG was available and capable of performing

• its function.

At the time of the event Salem Unit 2 was in Mode 4 with reactor coolant system temperature and pressure at a fraction of their normal operating values, such that the contained energy within the system was low. Additionally, procedures exist (and operators are trained) that provide the necessary guidance to mitigate accidents with less than the minimum required AC distribution; therefore, the safety consequences and implications of this event were minimal. CORRECTIVE ACTIONS TAKEN AND PROPOSED;

1. On July 2, 1997, the follow-up test was performed satisfactorily, the test equipment was removed, and the surveillance procedure was signed off. 2. Appropriate personnel have been held accountable for their actions in accordance with PSE&G disciplinary policy. 3. A memorandum has been issued to clarify Operations management's expectations regarding non-performance of procedure steps that require test equipment removal. NRC FORM 366A (4-95)

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NRC FORM 366A , U.S. NUCLEAR REGULATORY COMMISSION (4-95) FACILITY NAME (1) LICENSEE EVENT REPORT (LER) TEXT CONTINUATION DOCKET NUMBER (2) LER NUMBER (6) PAGE(3) 05000272 YEAR I SEQUENTIAL I REVISION NUMBER NUMBER 6 OF 6

• SALEM GENERATING STATION UNIT 1 97 -013 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17) CORRECTIVE ACTIONS TAKEN AND PRQPOSED:(cont'd

4. A Temporary Standing Order (TSO) was issued which requires that all declarations that a procedure or step, determined to be not applicable shall require the concurrence of two operators, at least one of whom shall be a supervisor, preferably SRO licensed.

5. The Operations Department Procedure on Procedure Use has been revised to incorporate the above stated TSO. 6. The electrical connection between the test equipment and the EDG cabinet is being modified by the addition of fuses to properly separate these electrical connections.

Until all the modifications are completed, the unmodified diesel will be considered inoperable with the test instrumentation connected.

7. A condition report (CR) has been issued to address the untimeliness of this report, as well as the poor communications amongst departments.

The evaluation of this CR will be presented to the _Corrective Action Review Board. 8. Generic guidance is being developed to provide appropriate direction for the installation of temporary test instrumentation into Operable plant equipment.

This action will be compieted by January 30, 1998. NRC FORM 366A (4-95)