05000311/LER-2004-001

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LER-2004-001, Failure to Take Proper Compensatory Containment Air Samples
Salem Generating Station Unit 2
Event date:
Report date:
Reporting criterion: 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
3112004001R00 - NRC Website

DOCKET (2)

PLANT AND SYSTEM IDENTIFICATION

Westinghouse — Pressurized Water Reactor Radiation Monitoring System (IL/-) * Energy Industry Identification System {EIIS) codes and component function identifier codes appear as (SS/CCC)

CONDITIONS PRIOR TO OCCURRENCE

Salem Unit 2 was in Mode 1 at approximately 100% reactor power. No additional equipment was out of service that contributed to this event.

DESCRIPTION OF OCCURRENCE

On February 4, 2004, the Containment Air Particulate Detector (APD) {IUDET) was declared inoperable and Technical Specification (TS) Action Statements 3.3.3.1 Action 24 and 3.4.7.1 were entered. Action 24 of TS 3.3.3.1 states to comply with the ACTION requirements of Specification 3.4.7.1. TS 3.4.7.1 Action states in part:

"...operation may continue for up to 30 days provided grab samples of the containment atmosphere are obtained and analyzed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the required gaseous and/or particulate radioactivity monitoring system is inoperable; otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />" Chemistry procedures require samples to be collected and analyzed approximately every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to ensure the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period is not exceeded. On February 13, 2004, when the required compensatory samples were being collected at approximately 2155 hours0.0249 days <br />0.599 hours <br />0.00356 weeks <br />8.199775e-4 months <br />, it was identified that containment isolation valve 2VC12 had been tagged closed. Valve 2VC12 was tagged closed at approximately 1130 on February 12, 2004. With this valve closed, representative samples of the containment atmosphere could not be obtained. Samples had been collected with the valve closed on February 12, 2004, at 2120 hours0.0245 days <br />0.589 hours <br />0.00351 weeks <br />8.0666e-4 months <br /> and February 13, 2004, at 0925 hours0.0107 days <br />0.257 hours <br />0.00153 weeks <br />3.519625e-4 months <br />. The last sample collected with valve 2VC12 open was on February 12, 2004, at 0945 hours0.0109 days <br />0.263 hours <br />0.00156 weeks <br />3.595725e-4 months <br />. Therefore, a period of approximately 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> elapsed between representative samples of the containment atmosphere being obtained contrary to TS requirements. This report is being made in accordance with 10CFR50.73(a)(2)(i)(B).

CAUSE OF OCCURRENCE

The cause of this event is attributed to personnel error by the Chemistry Technicians that performed the sampling activities on February 12 and 13, 2004. Chemistry procedure SC.CH-AB.CBV-0243 provides direction to the technicians on how to obtain a sample when the APD sample pump is in- service or out of service. The procedure requires the Chemistry Technicians to ask Operations to verify that valves 2VC11 and 2VC12 are open, or to open these valves. A contributing cause to this event was that procedure SC.CH-AB.ABV-0243 was characterized as a Category II procedure.

Although Category II procedures with specific procedure steps are required to be performed in sequence, documentation of completion of the steps in the procedure is not required.

DOCKET (2)

PRIOR SIMILAR OCCURRENCES

A review of LERs for Salem and Hope Creek for the previous two years did not identify any previous reportable occurrences as a result of a failure to follow procedures.

SAFETY CONSEQUENCES

There were no safety consequences associated with the failure to take containment atmosphere grab samples from February 12 at 0945 to February 13 at 2155. There was no indication of any increased Reactor Coolant System leakage or containment activity based on other alternate indications. Grab samples were collected within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of discovery of the missed samples and the results of these samples indicated no changes in Containment particulate or gaseous activity levels.

A review of this event determined that a Safety System Functional Failure (SSFF) as defined in Nuclear Energy Institute (NEI) 99-02 has not occurred.

CORRECTIVE ACTIONS:

1. Chemistry personnel involved with this event have been held accountable in accordance with PSEG policies.

2. Procedural compliance was reinforced with Salem Chemistry personnel.

3. Procedure SC.CH-SA.CBV-0243 was revised to change the use category of the procedure from Category II to Category I to ensure documentation of procedure step completion prior to proceeding to the next step of the procedure.

COMMITMENTS

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