ML18093B412

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LER 88-026-00:on 881229,plant Vent Effluent Release Composite Iodine & Radioactive Particulate Samples Not Obtained as Required by Tech Spec 3.3.3.9,Table 3.3-13. Caused by Inadequate Administrative control.W/890126 Ltr
ML18093B412
Person / Time
Site: Salem PSEG icon.png
Issue date: 01/26/1989
From: Miller L, Pollack M
Public Service Enterprise Group
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
LER-88-026-01, LER-88-26-1, NUDOCS 8902010003
Download: ML18093B412 (5)


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APPROVED OMI NO. 31110-01CM EXPIRES: S/3111111 LICENSEE EVENT REPORT (LER) l FACILITY NAME 111 ~ICl5T NUM:UI (2) I ~-~& !:ii Salem Generating Station - Unit 2 0151010 IOI 31111*,ioF0 j4 TITLE t*l.

Tech. Spec. 3.3.3.9 Action 36 Non-Compliance Due To Inadequate Administrative Control EVENT DATE Ill LEA NUMllEA Ill REPORT DATE 171 OTHER FACILITIES INVOLVED Ill MONTH QAV VEAR VEAR tl SE~~~~~:;'L tt ~~':..':i~ MONTH DAV YEAR FACILITY NAMES DOCKET NUMBER(~)

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  • I.*.. 1ppl'Oxlm1twly fiftwen rlngl**llM** typewrimn /inn) 1111 Betwee~ 12/29/88 and 12/30/88, Plant Vent effluent release composite iodine and radioactive particulate samples were not obtained as required by Technical Specification 3.3.3.9 Table 3.3-13 Action Statement 36. This action statement allows efflue.nt releases to continue provided composite iodine and particulate samples are obtained. Plant Vent composite iodine and particulate samples are normally obtained by pulling a sample from the 2R41 (Plant Vent low level radiation monitor) flow path. When the 2R41 sample pump *becomes inoperable, the flow through the sampling line recirculates thereby confounding the sample. In this situation, obtaining a representative composite sample requires the composite sample outlet line be disconnected and the flow be directed through a poly bottle to the Auxiliary Building. The root cause of this event has been attributed to inadequate administrative control. Operations Department personnel were not made aware of the necessity for entry into action statement 36 upon the loss of flow through the 2R41 plant vent monitor.
  • Operations Department procedure(s), for responding to a loss of flow to the plant vent 2R41 monitors, will be revised. The procedure(s) will address the need to contact Chemistry Department personnel to disconnect the composite sample pump outlet line. This event will be reviewed with applicable Operations Department personnel. This event will be.reviewed by the Nuclear Training Center for incorporation into applicable training programs. ,. , , .. _,;

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

  • PAGE Unit 2

~-------~

5000311 88-026-00

- - - - - - - - - - - - - - -of 4 2

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

IDENTIFICATION OF OCCURRENCE:

Technical Specification 3.3.3.9 Table 3.3-13 Action 36 Non-Compliance Due To Inadequate Administrative Control Event Dates: 12/29/88 Report Date: 1/26/89 This report was initiated by Incident Report No.88-538.

CONDITIONS PRIOR TO OCCURRENCE:

Mode 5 Reactor Power 0%- - Unit Load 0 MWe Between December 29, 19~8 and December *30, 1988, Plant Vent (VL}

effluent release composite iodine and radioactive particulate samples were not obtained as required by Technical Specification 3.3.3.9 Table 3.3-13 Action Statement 36. This action statement allows effluent releases to continue provided composite* iodine and particulate samples are obtained.

Plant Vent composite iodine and particulate samples are routinely obtained by pulling a sample from the 2R41 (Plant Vent low level radiation monitors) flow path. When the 2R41 sample pump becomes inoperable, the flow through the composite sampling line recirculates thereby confounding the sample. In this situation, obtaining a representative composite sample requires the composite sample outlet line be disconnected and the flow be directed through a poly bottle to the Auxiliary Building.

Technical Specification 3.3.3.9 Table 3.3-13 Action 36 states:

"With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue provided samples are continuously collected with auxiliary sampling equipment as required in Table 4.11-2."

On December 29, 1988 at 2025 hours0.0234 days <br />0.563 hours <br />0.00335 weeks <br />7.705125e-4 months <br />, the 2R41 pump was found to be inoperable. Technical Specification 3.3.3.9 Table 3.3-13 Action Statement 31 was entered. The pump was returned to service at 0900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> the next day and the Action Statement was terminated. During this period, the composite sample line was not modified to prevent recirculating flow.

Technical Specification 3.3.3.9 .Table 3.3-13 Action 31 states:

LICENSEE EVENT REPORT (LER) TEXT CONTINUATION Salem Generating Station DOCKET NUMBER LER NUMBER PAGE Unit 2 5000311

~~~~~~~-

88-026-00 3 of 4

-~~~~~~~~~

DECRIPTION OF __ OG~JJRR~NCE: (cont'd)

"With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, the contents of the tank(s) may be r~leased to the environment provided that prior to initiating the release:

a. At least two independent samples of the tank's contents are analyzed, and
b. At least two technically qualified members of the Facility Staff indepe-ndently verify the release rate calculations and discharge valving lineup; Otherwise, suspend release -of radioactive effluents via this pathway."

APPARENT.CAUSE OF OCCURRENCE:

The root cause of this event has been attributed to inadequate administrative control. Operations Department personnel were not made aware of the necessity for entry into action statement 36 upon the loss of flow through the 2R41 plant vent monitor. As indicated in the Descrip~ion of Occurrence section, the loss of flow will cause the composite sample line to recirculate and not adequately sample plant vent effluent releases. Chemistry personnel were subsequently not informed. The composite sample discharge line was not disconnected.

ANALYSIS OF OCCURRENCE:

The Plant Vent directs effluent discharges to the environment. These discharges include Waste Gas System IWEJ effluent, Fuel Handling Building Exhaust {VGI, Auxiliary Building Exhaust {VFI, Containment purge fVAI and Containment Pressure/Vacuum Relief. These various effluent discharges are HEPA filtered and charcoal filtered (as applicable) prior to discharging to the Plant Vent. The Waste Gas System effluent is sampled and analyzed independently prior to discharge to the Plant Vent.

Containment purge is directed to the Plant Vent via the Auxiliary Building Ventilation System.

The 2R41 Plant Vent Monitors continuously monitor the_ plant vent effluent releases. Channel A monitors radioactive particulates, Channel B monitors radioactive iodines and Channel C monitors radioactive noble gases. Channels A and C provide an alarm signal which will cause the automatic isolation of the Containment Pressure/Purge - Vacuum Relief System and closure of the WG41 valve (Waste Gas Decay Tank Vent Control Valve).

The R16 channel corroborates indications for the R41C channel.

However, the R16 channel does not have any automatic interlocking

LICENSEE EVENT REPORT (LER) TEXT CONTINUATION

, _ __ __c.___ _ _ _ __

Salem Generating Station DOCKET NUMBER 'LER NUMBER PAGE "CJ.~~ t 2 --***--'---** ---------*----~_9_9_o_)_J,1.___________?_~-:-.9.2~_:-_9_Q_________ 4_Q_:t__4___ _

M'.IA4¥_~-~-~--_Qf_. O~~.tJ~R_EN_<;:_E =--~-L~.<?n._t .'.gl features. Techndcal Specification 3.3.3.9 Table 3.3-lJ requires either the 2R41C to be operable or* the 2R16 monitor to* be operable.

During this event, the 2R16 monitor was operable.

During this event, no Containment purge nor Waste Gas System

  • discharge occurred~ Also*, Plant Vent monitoring including the high range Plant Vent monitors (2R45 channels) and the 2R16 channel were

- operable. The various area radiation monitors for the Fuel Handling Building and the Auxiliary Buildirig were operable. Also, during s~~cific wor~ activiti~s, local air sampling was conducted ~s required per radiation protection work practices. Therefore, this event did not affect the health of the public. However~ this. event is reportable in acco~dance with Code of Federal Regulations 10CFR

  • 50.73(a) (2) (i) (B) since the Plant Ven~ effluent releases were not terminated when the tiormal composite sampling alignment became

_inadequate.

Operations Department procedure(s) for responding to a loss of flow tb th~ plant vent 2R41 monitors will be revised. The procedure(s) will address the need to contact Chemistry Department personnel to disconnect the composite sample pump outlet line.

This event will be reviewed with applicable. Operations Department personnel.

This event will be reviewed by the Nuclear Training Center for incorporation intb applicable training programs.

1
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General Manager -

Salem Operations MJP:pc SORC Mtg.89-004

Pub I ic Service Electric and Gas Company P.O. Box E Hancocks Br*idge, New Jersey 08038 Salem Generating Station January 26, 1989 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

Dear Sir:

SALEM GENERATING STATION LICENSE NO. DPR-75 DOCKET NO. 50-311 UNIT NO. 2 LICENSEE EVENT REPORT 88-026-00 This Licensee Event* Report is being submitted pursuant to the requirements of the Code of Federal Regulations 10CFR 50.73 (a) (2} (i} (B}. This report is being submitted within thirty (30}

days of discovery.

Sincerely yours, L. K. Miller General Manager -

Salem Operations MJP:pc Distribution