05000272/LER-2008-002

LER-2008-002,

Docket Number
Event date:	12-09-2008
Report date:	02-07-2009
Reporting criterion:	10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
2722008002R00 - NRC Website

PLANT AND SYSTEM IDENTIFICATION

Westinghouse — Pressurized Water Reactor Containment Spray/Safety Valves {BE/RV}* *Energy Industry Identification System (EIIS) codes and component function identifier codes appear as {SS/CC}

CONDITIONS PRIOR TO OCCURRENCE

The plant was in Mode 1. No structures, systems, or components were inoperable at the time of discovery that contributed to the event.

DESCRIPTION OF OCCURRENCE

On September 24, 2008, it was identified that the valve grouping for the pressure relief devices (vacuum breakers) on the Containment Spray Additive Tank {BE/RV}, i.e., valves 1CS12 and 1CS13, had not been tested as required by the American Society of Mechanical Engineers (ASME) Code and they had exceeded their required Technical Specification (TS) code frequency. The surveillance for the 1CS12 valve was scheduled and the valve was swapped out with a new replacement vacuum breaker valve.

This work was completed on October 9, 2008. In accordance with plant procedures and ASME Code °Ma-1988, Part 1, components that are replaced shall be as-found tested within three (3) months after being removed.

On December 9, 2008, it was discovered that the old 1CS12 vacuum- breaker valve, removed during the fall outage for as-found testing, could not be located. After discussion with the Maintenance department, it appears that this component was inadvertently disposed of prior to the as-found testing scheduled date.

Since the surveillance on the replaced valve could not be performed,. the TS 4.0.5 surveillance is considered a test failure.

CAUSE OF OCCURRENCE

The inability to perform the required TS surveillance test was caused by a failure to follow the written instructions provided in the work order to retain these valves for an as-found test. Since the surveillance on the removed vacuum breaker valve could not be performed, the TS 4.0.5 surveillance is considered a test failure.

�NRC FORM 366 (9-2007) PRINTED ON RECYCLED PAPER

PRIOR SIMILAR OCCURRENCES

A review of Salem LERs since 2005 identified no occurrences where a valve requiring TS surveillance testing had been misplaced prior to the test. This, review also identified no occurrences where the failure to follow instructions had resulted in a reportable event.

SAFETY CONSEQUENCES AND IMPLICATIONS

The Containment Spray Additive Tank (SAT) pressure relief valves are not specifically credited in the UFSAR Chapter 15 safety analyses for their pressure (vacuum) relief benefits. The 100% redundant SAT pressure relief valves (i.e., CS12 and CS13) prevent a vacuum from forming in the SAT by maintaining atmospheric pressure on the top of the fluid in the tank during post-accident operations.

Although the 1CS12 valve was not available for as-found testing, the redundant 1CS13 vacuum breaker valve was removed for expanded scope testing. Testing determined that the removed 1CS13 valve did not meet the ASME Code requirements, but the valve would have provided vacuum relief capability for the SAT. The safety function of the system would not have been affected.

A review of this event determined that a Safety System Functional Failure (SSFF) as defined in NEI 99-02, Regulatory Assessment Performance Indicator Guidelines, did not occur. This event did not prevent the ability of a system to fulfill its safety function to either shutdown the reactor, remove residual heat, control the release of radioactive material, or mitigate the consequences of an accident.

CORRECTIVE ACTIONS:

1. All Unit 1 Containment Spray pressure relief devices were replaced with new vacuum breaker valves 2. Expanded scope test of the remaining valve in this group, i.e., 1CS13, which was removed and replaced with a new valve, was completed. The removed pressure relief valve would have provided vacuum relief capability for the SAT.

3. All Unit 2 Containment Spray pressure relief devices were checked and confirmed to be within periodicity of their testing requirements.

4. The maintenance plans for these valves will be revised to include as-found testing of removed vacuum breaker valves.

COMMITMENTS

The corrective actions cited in this LER are, voluntary enhancements and do not constitute commitments.