ML18100B157

LER 94-008-00:on 900828,determined That Several Channel Functional Testing for Both Units May Have Been Performed Late Due to Personnel Error.Surveillance Procedure Has Been revised.W/940622 Ltr

ML18100B157
Person / Time
Site:	Salem
Issue date:	06/22/1994
From:	Hagan J, Pastva M Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-94-008, LER-94-8, NUDOCS 9406280309
Download: ML18100B157 (7)

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June 22, 1994 U. s. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

Dear Sir:

SALEM GENERATING STATION LICENSE NO. DPR-70 DOCKET NO. 50-272 UNIT NO. 1 LICENSEE EVENT REPORT 94-008-00 This Licensee Event Report is being submitted pursuant to the requirements of Code of Federal Regulation 10CFR50.73(a)(2) (i) (B).

Issuance of this report is required within thirty (30) days of event discovery.

Sincerely.yours, J. J. Hagan General Manager -

Salem Operations MJPJ:pc Distribution

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9406280309 940622 PDR ADOCK 05000272 S PDR 95-2189 A EV 7-92

. U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150-0104 EXPIRES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS. FORWARD "LICENSEE EVENT REPORT (LER) COMMENTS REGARDING BURDEN ESTIMATE TO THE INFORMATION AND RECORDS MANAGEMENT BRANCH (MNBB 7714), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555-0001, AND TO THE PAPERWORK REDUCTION PROJECT (3150-0104). OFFICE OF (See reverse for required number of digits/characters for each block) MANAGEMENT AND BUDGET, WASHINGTON, DC 20503.

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

Salem Generating Station - Unit 1 05000 272 1 OF nc; TITLE(4l Quarterly Channel Functional Testing Of Position Indication For Power Operated Relief Valves Missed On Both Units. -

EVENT DATE 15\ LER NUMBER (6 REPORT NUMBER (7) OTHER FACILITIES INVOLVED (8)

FACILITY NAME DOCKET NUMBER SEQUENTIAL REVISION MONTH DAY YEAR YEAR MONTH DAY YEAR NUMBER NUMBER Salem Unit 2 05000 311 FACILITY NAME DOCKET NUMBER 08 28 90 94 008 00 06 22 94 05000 OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check one or more (11 l MODE (9) 4 20.402(b} ~~0.405(c) 50.73(a)(2)(iv) 73.71 (b) l!==P=o=w=E=R=:::;:::====:t-t-2:::0:-:.4:::-0::--:5(:-:a)-::(1:-;-)(::-:-i)------r---r:.50.36(c}(1) 50.73(a}(2) (v) 73. 71 (c)

LEVEL (10) 000 20.405(a)(1)(ii) 50.36(c)(2) 50.73(a)(2)(vii) OTHER 1--+--_..:....:.....:....;...;c...;..._ _ _ _ _--l-=+--'--'-'-'-------+--+-----:-.,...,..,....,..,.,-.-:--.,.------I

-20_.4_0_5..:.(a..:.).:...(1.:...:)(c...iii:....)------l-X-1--50_.7_3....:.(a....:.).:..(2.:..)(:.....:i)------+---l'-5-0_.7_3.;_(a'-'}('-2)-'-(v_ii.:..i)('-'A'-')- - - l below and (Specify in in Text, NRC Abstract 20.405(a) (1 )(iv) 50.73(a)(2){ii) 50.73(a)(2){viii)(B) Form 366A) 1-20.405(a) (1) (v) 50.73(a)(2)(iii) 50.73{a)(2)(x)

LICENSEE CONTACT FOR THIS LER 12}

- NAME TELEPHONE NUMBER (Include Area Code)

M. J. Pastva, Jr. - LER Coordinator (609) 339-5165 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

REPORTABLE REPORTABLE CAUSE SYSTEM COMPONENT MANUFACTURER CAUSE SYSTE~< COMPONENT MANUFACTURER TO NPRDS TO NPRDS SUPPLEMENTAL REPORT EXPECTED (14) EXPECTED MONTH DAY YEAR SUBMISSION I

YES NO (If yes, complete EXPECTED SUBMISSION DATE) DATE (15}

x ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) (16)

From 8/90 through 4/94, quarterly channel functional testing of position indication for both Units' power operated relief valves (PORVs), 1(2)PR1 and 1(2)PR2, was performed late on four occasions on Unit 1 and six on Unit 2. The testing is specified by Technical Specification (TS) Table 4.3-11, Item 12. This event is attributed to personnel error, which resulted from inattention to detail: during review/implementation of Generic Letter (GL) 90-06 it was not recognized that revising TS Table 4.3-11 was necessary, and a surveillance procedure revision eliminated the mechanism by which TS Table 4.3-11, Item 12 was met. The procedure has been revised to ensure TS compliance and the requirement has been reaffirmed with licensed Operations personnel. A license change request (LCR) is being submitted to revise TS Table 4.3-11, Item 12 to meet the intent of the GL. A verification audit of TS Table 4.3-11 will be performed to ensure all requirements are being procedurally met. The importance of adequate procedure reviews to ensure compliance with TS will be stressed with appropriate personnel. This report will be reviewed by appropriate personnel to ensure their awareness of the importance of attention to detail when reviewing procedure requirements involving LCRs.

NRC FORM 366 (5-92)

REQUIRED NUMBER OF DIGITS/CHARACTERS FOR EACH BLOCK BLOCK *NUMBER OF TITLE NUMBER DIGITS/CHARACTERS 1 UP TO 46 FACILITY NAME 8 TOTAL 2 DOCKET NUMBER 3 IN ADDITION TO 05000 3 VARIES PAGE NUMBER 4 UP TO 76 TITLE 6 TOTAL 5 EVENT DATE 2 PER BLOCK 7 TOTAL 2 FOR YEAR 6 LER NUMBER 3 FOR SEQUENTIAL NUMBER 2 FOR REVISION NUMBER 6 TOTAL 7 REPORT DATE 2 PER BLOCK UP TO 18 -- FACILITY NAME 8 OTHER FACILITIES INVOLVED 8 TOTAL -- DOCKET NUMBER 3 IN ADDITION TO 05000 9 1 OPERATING MODE 10 3 POWER LEVEL 1

1* 1 REQU!REMENTS OF 10 CFR CHECK BOX THAT ,APPLIES UP TO 50 FOR NAME 12 - LICENSEE CONTACT 14 FOR TELEPHONE CAUSE VARIES 2 FOR SYSTEM 13 4 FOR COMPONENT EACH COMPONENT FAILURE 4 FOR MANUFACTURER NPRDS VARIES 1

14 SUPPLEMENTAL REPORT EXPECTED -

CHECK BOX THAT APPLIES 6 TOTAL 15 EXPECTED SUBMISSION DATE 2 PER BLOCK

LICENSEE EVENT REPORT (LER) TEXT CONTINUATION Salem Generating Station DOCKET NUMBER LER NuMBER PAGE.

Unit 1 5000272 94-008-00 2 of 5 PLANT AND SYSTEM IDENTIFICATION:

Westinghouse - Pressurized Water Reactor-Energy Industry Identification system (EIIS) codes are identified in the text as {xx}

IDENTIFICATION OF OCCURRENCE:

Quarterly Channel Functional Testing Of Position Indication For Power Operated Relief Valves Missed On Both Units Event Date: 8/28/90 Discovery Date: 5/24/94 Report Date: 6/22/94 This report was initiate.d by Incident Report No.94-137.

CONDITIONS AT TIME OF DISCOVERY:

Unit 1 The Unit was in a forced outage (see LER 272/94-007-00).

(Mode 4, Reactor Power -o- %, Unit Load -o- MWe)

Unit 2 (Mode 1, Reactor Power 100%, Unit Load 1100 MWe)

DESCRIPTION OF OCCURRENCE:

Over the period of.August 1990 through April 1994, quarterly channel functional testing of position indication for both Units' power operated relief valves (PORVs), 1(2)PR1 and 1(2)PR2 {AB}, was performed late, including 25% allowance per Technical Specifications (TS) 4.0.2, on four occasions on Unit 1 and six on Unit 2:

Unit 1 Due Date Performed Date December 24, 1990 March 29, 1991 August 5, 1991 September 20, 1991 May 16, 1993 July 13, 1993

-April 4, 1994 April 18, 1994

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LICENSEE EVENT REPORT (LER) TEXT CONTINUATION Salem Generating Station DOCKET NUMBER LER NUMBER PAGE Unit 1 . 5000272 94-008-00. 3 of 5 DESCRIPTION OF OCCURRENCE:* {cont'd)

Unit 2 Due Date Performed *Date August 28, 1990 September 13, 1990 April 17, 1991 May 15, 1991

~September 7, 1991 October 3, 1991 April 22, 1992 . May 12, 1992 December 13, 1992 January 31, 1993 August 22, 1993 October 15, 1993 The required testing is specified in TS Table 4. 3-11, Item 12 and has.

a specified frequency of once every 92 days in MODES 1, 2, and 3.

ANALYSIS OF OCCURRENCE:

While reviewing a surveillance procedure revision as part of a Technical Specification amendment to meet Generic Letter (GL) 90:-06, it was discovered that in several instances channel functional testing of position indication for both Units PORVs may have been performed late. On May 24, 1994, it was determined the surveillance frequency had been missed at various times on both Units (see DESCRIPTION OF OCCURRENCE section).

The GL recommends the PORVs not be cycled in Modes 1 and 2. This is consistent with American Society of Mechanical Engineers (ASME) Code Section XI, which provides, relief. from testing certain valves when it is determined to be impractical for the required operating mode. As such, during 1990 the surveillance procedure for cycling the PORVs to meet TS 4.0.5 was revised, in accordance with the recommendations of the GL, to not cycle PORVs when at power. However, during review of the GL to identify applicable TS for revision, it was not recognized that a License Change Request (LCR) to revise TS Table 4.3-11 was necessary. In addition, it was not recognized that revising the surveillance procedure inadvertently eliminated the mechanism by which TS Table 4.3-11, Item 12 was being met. Contributing to this oversight was lack of reference within the procedure to TS Table 4.3-11, Item 12.

Following implementation of a design change package (DCP) to the PORV

. actuators, post-installation testing in 1991 required periodic (every 92 days) cycling of the PORVs. This testing was controlled by the TS 4.0.5 surveillance procedure however, the frequency of this testing conflicted with the GL recommendations. In order to ensure appropriate management attention, the surveillance procedure was revised to include a requirement to obtain.authorization from the

LICENSEE EVENT REPORT (LER) TEXT CONTINUATION Salem Generating Station DOCKET NUMBER LER NUMBER PAGE Unit 1 5000272 94-008-00 4 of 5 ANALYSIS OF OCCURRENCE: (cont'd)

Operations Manager (OM) or Operating Engineer (OE), prior to cycling the valves in Modes 1 and 2. However, the wording used to convey this requirement made cycling of the PORVs appear to be conditional.*

In June of 1993, the TS 4.0.5 surveillance procedure was upgraded and revised, including a change that identified that performing the procedure satisfied TS Table 4.3-11, Item 12. However, as the result of inadequate procedure review the body of the procedure and attachments did not provide adequate direction that the PORVs are required to be cycled every 92 days when in Modes 1 and 2.

APPARENT CAUSE OF OCCURRENCE:

This event is attributed to "Personnel Error", as classified in*

Appendix B of NUREG-1022, which resulted from inattention to detail.

During the review and implementation of the GL it was not recognized that an LCR to revise TS Table 4.3-11 was necessary. In addition, it was not recognized that revising the procedure to comply with the GL

• eliminated the mechanism by which TS Table 4. 3-11, Item 12 was met ..

PREVIOUS OCCURRENCES:

Review of documentation shows_ this event is an isolated occurrence.

SAFETY SIGNIFICANCE:

This event did not affect the health and safety of the public. It is reportable pursuant to the requirements of 10CFR50.73(a(2) (i)) (B).

• The longest periqd the surveillance was performed late on each Unit was 95 and 53 days, respectively. However, the safety significance was minimal because:

1) In each case, position indication of the PORVs was determined to be operable when the surveillance was performed.

2) Backup instrumentation to the PORV position indication is (was) available in the Control Room, which would indicate the PORV not fully closed. This consists of indication for

.PORV tailpipe temperature and Pressurizer Relief Tank (PRT) pressure, temperature, and level.

3) NUREG-1431, Volume 1, "Standard Technical Specifications Westinghouse Plants", issued September 1992, only requires

LICENSEE EVENT REPORT (LER) TEXT CONTINUATION Salem Generating' Station DOCKET NUMBER L'.ER NUMBER PAGE Unit 1 5000272 94-008-00 5 of 5 SAFETY SIGNIFICANCE: (cont'd)

Regulatory Guide. (RG) 1. 97 instrumentation classified as either Type A or non-Type A, Category 1 be included in TS Table 4.3-11. The Salem PORV position indication is.

classified as Type D, category 2. Therefore, inclusion of this* line item is not required by NUREG-1431.

4) The ASME Code Section XI requires position indication verification every two years.

CORRECTIVE ACTION:

T~e surveillance procedu~e has been revised to cla~ify the*

requirement to cycle the PORVs until TS are appropriately revised.

In addition, the requirement has been reaffirmed with Licensed Operations personnel.

An appropriate LCR is being submitted to revise the frequency of the PORV position indication surveillance to at least once per every 18 months, thereby *meeting the intent of the GL.

A verification audit will be performed to ensure all requirements.of TS Table 4.3-11 are being procedurally met.

The importance of adequate procedure reviews to ensure compliance with TS will be stressed with appropriate personnel.

This report will be ~eviewed by appropriate personnel to ensure their awareness of the importance of attention to detail when reviewing procedure requirements involving LCRs.

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Salem Operations MJPJ:pc SORC Mtg.94-050