ML18102A466

LER 96-022-00:on 960912,containment Radiation Monitor Setpoints Not IAW TS Requirements.Caused by Inadequate Review.Revised Procedure & Continued Previously Defined TS requirements.W/961014 Ltr

ML18102A466
Person / Time
Site:	Salem
Issue date:	10/14/1996
From:	Garchow D, Hassler D Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-96-022-01, LER-96-22-1, LR-N96315, NUDOCS 9610220091
Download: ML18102A466 (5)

Text

e OPS~G Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038-0236 Nuclear Business Unit OCT 141996 LR-N96315 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

LER 272/96-022-00 SALEM GENERATING STATION - UNIT 1 FACILITY OPERATING LICENSE NO. DPR-70 DOCKET NO. 50-272 This Licensee Event Report entitled "Containment Radiation Monitor Setpoints Not In Accordance with Technical Specifications Requirements" is being submitted pursuant to the requirements of the Code of Federal Regulations 10CFR50. 73 (a) (2) (i) (B).

Sincerely,

/ff/'f-/1~~how General Manager -

Salem Operations Attachment DVH C Distribution LER File 3.7

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9610220091 961014 i' PDR ADOCK 05000272 S PDR 95-2168 REV. 6/94

Document Control Desk LR-N96315 Attachment A The following represents the commitments that Public Service Electric

& Gas (PSE&G) made to the Nuclear Regulatory Commission (NRC) relative to this LER (272/96-022-00). The commitments are as follows:

1. The procedure for the containment monitor Mode 6 alarm setpoint will be revised to comply with the Technical Specifications requirements prior to entry into Mode 6 for Salem Units 1 and 2.

2. A Technical Specification Surveillance Improvement Project (TSSIP) has been initiated for Salem Units 1 and 2. The scope and content of the TSSIP program was described previously in LER 311/95-008-00. The TSSIP review is expected to be completed by December 31, 1997.

NRCFORM366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150-0104 (4-96) EXPIRES IM/30/98 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS MANDATORY INFORMATION COLLECTION REQUEST: 50.0 HRS.

REPORTED LESSONS LEARNED ARE INCORPORATED INTO THE LICENSEE EVENT REPORT (LER) LICENSING PROCESS AND FED BACK TO INDUSTRY. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE INFORMATION AND RECORDS MANAGEMENT BRANCH (T~ F33Js~ NUCLEAR (See reverse for required number of REGULATORY COMMISSION, WASHINGTON, DC 20 , AND TO THE PAPERWORK REDUCTION PROJECT (3150-0104), OFACE OF digits/characters for each block) MANAGEMENT AND BUDGET, WASHINGTON, DC 20503.

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

SALEM NUCLEAR GENERATING STATION, UNIT 1 05000272 1 OF 3 TITLE (4)

Containment Radiation Monitor Setpoints Not In Accordance With Technical Specifications Requirements EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (8)

MONTH DAY YEAR YEAR I SEQUENTIAL NUMBER

'REVISION NUMBER llONTH DAY YEAR FACILITY NAME Salem Unit2 DOCKET NUMBER 05000311 09 12 96 96 - 022 - 00 10 14 96 FACILITY NAME DOCKET NUMBER 05000 OPERATING N 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 000 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 20.2203(a)(2)(ii) 20.2203(a)(4) 50. 73(a)(2)(iv) OTHER 20.2203(a)(2)(iii) 50.36(c)(1) 50. 73(a)(2)(v) S~~ln Abstract below or In C Form 366A 20.2203(a)(2)(iv) 50.36(c)(2) 50. 73(a)(2)(vii)

LICENSEE CONTACT FOR THIS LER (12)

NAME TELEPHONE NUMBER (Include Area Code)

Dennis v. Hassler, LER Coordinator 609-339-1989 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TONPRDS II

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• =-=*=*=*=-=*=*=*=*=-=*:*:*:*

CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TONPRDS 111111111111111111 SUPPLEMENTAL REPORT EXPECTED (14) EXPECTED MONTH DAY YEAR IYES XINO SUBMISSION (lfyH, complete EXPECTED SUBMISSION DATE). DATE (15)

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

On September 12, 1996 a review by the Chemistry Department determined that the Containment Radiation Monitors R12A and RllA {IL/MON} were set during Mode 6 at a higher level than the Technical Specifications limit. Technical Specification 3.3.3.1 and Table 3.3-6 require the Containment radiation process monitors to be set at less than or equal to two times background during Mode 6. In 1991, a method was developed to define background at a setpoint that reflects radiation levels for given plant conditions. The setpoint was chosen based on expected monitor response of activity from a potential source, usually the RCS or the primary side of a steam generator. A procedure was developed and approved based on these principles. A recent review determined the procedure did not comply with Technical Specification requirements.

The cause of this occurrence was determined to be less than adequate review of the procedure change with regard to the Technical Specification requirements.

Corrective actions include revising the procedure and continuing the previously defined Technical Specification Surveillance Improvement Project.

This event is reportable under 10 CFR 50.73(a) (2) (i) ( B) ' any condition prohibited by the plant's Technical Specification.

NRC FORM 366 (4-95)

• • NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (4-95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3) 05000272 YEAR I SE~lY:~~AL I~'mi~~~ 2 OF 3 Salem Generating Station, Unit 1 96 - 022 00 TEXT (If more apace ia required, use additional copies of NRC Form 366A) (17)

PLANT AND SYSTEM IDENTIFICATION Westinghouse - Pressurized Water Reactor Containment Radiation Monitoring System {IL/MON)*

• Energy Industry Identification System EIIS codes and component function identifier codes appear as SS/CCCS CONDITIONS PRIOR TO OCCURRENCE At the time of identification, Salem Units 1 and 2 were shutdown and defueled.

Radiation monitors Rll and R12 were inoperable due to a design change to upgrade the Radiation Monitoring System computer system.

DESCRIPTION OF OCCURRENCE On September 12, 1996 a review by the Chemistry Department determined that the Containment radiation monitors Rl2A and RllA {IL/MON} were set during Mode 6 at a higher level than the Technical Specifications limit. Technical Specification 3.3.3.1 and Table 3.3-6 require the Containment radiation process monitors to be set at less than or equal to two times background during Mode 6. This condition existed since February 1991.

As a result of Engineered Safety Feature (ESF) actuations in 1990 and 1991, attributed to unrealistic radiation monitor setpoints for plant maintenance activities, a method was developed to define background at a higher setpoint that would allow plant maintenance activities to continue. The setpoint was chosen based on expected monitor response of activity from a potential source, usually the reactor coolant system or the primary side of a steam generator.

The activity for a potential release to the environment was compared to limits specified in the Offsite Dose Calculation Manual (ODCM) to ensure regulatory dose limits would not be exceeded. A procedure was developed and approved based on these principles.

The procedure was used until an evaluation determined the procedure did not comply with Technical Specification requirements. This evaluation was performed in response to a Chemistry department self-assessment performed in June 1996.

CAUSE OF OCCURRENCE The cause of this occurrence was determined to be less than adequate review of the procedure change with regard to the Technical Specification requirements.

The procedure change was based on an interpretation of background for expected outage conditions.

NRC FORM 366A (4-95)

NRC FORM 366A (4-96)

• LICENSEE EVENT REPORT (LER)

U.S. NUCLEAR REGULATORY COMMISSION TEXT CONTINUATION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3) 3 OF 3 Salem Generating Station, Unit 1 96 - 022 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

PRIOR SIMILAR OCCURRENCES In the past two years there have been two LERs that addressed events where Technical Specification interpretations were inappropriate. LER 311/96-003-00 identified an occurrence where an erroneous determination was made regarding Technical Specification applicability. The Technical Specifications contained a surveillance for an auto-start feature in the FHB Ventilation System that was not installed. Corrective actions were to install the auto-start feature and the continuation of the Technical Specification Improvement Project.

LER 311/96-002-00 identified that the Unit 2 Waste Gas System was taken out of service for maintenance and was vented to atmosphere. Technical Specification 3.11.2.5 was not considered applicable at the time because the system was not being used for waste gas storage. However, further evaluation by Plant Management and Licensing personnel determined that this interpretation was not correct. One of the corrective actions had Operations Management emphasize the need to comply with the intent and the exact wording of the Technical Specifications, and to immediately address any issues where the intent and the wording are in conflict.

SAFETY CONSEQUENCES AND IMPLICATIONS There were no safety consequences for this condition. The purpose of the applicable Technical Specifications in Mode 6 is detection and control of fuel movement accidents. The higher setpoints permitted a higher concentration of noble gas to be released to the Containment. The higher setpoints did not exceed the limits specified in the Radiation Monitoring System Manual and therefore, the doses would not exceed regulatory limits. For this event, there was no impact on the public health and safety.

CORRECTIVE ACTIONS

1. The procedure for the containment monitor Mode 6 alarm setpoint will be revised to comply with the Technical Specification requirements prior to entry into Mode 6 for Salem Units 1 and 2.

2. A Technical Specification Surveillance Improvement Project (TSSIP) has been initiated for Salem Units 1 and 2. The scope and content of the TSSIP program was described previously in LER 311/95-008-00. The TSSIP review is expected to be completed by December 31, 1997.

NRC FORM 366A (4-95)