ML18102A550

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LER 96-013-00:on 961010,surveillance for Performing Tritium Grab Samples When Refueling Canal Is Flooded Was Missed. Caused by Inadequate Implementation of TS Requirements. Corrective Actions Include Procedure revs.W/961106 Ltr
ML18102A550
Person / Time
Site: Salem PSEG icon.png
Issue date: 11/06/1996
From: Garchow D, Hassler D
Public Service Enterprise Group
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-96-013-02, LER-96-13-2, NUDOCS 9611140312
Download: ML18102A550 (5)
v • d • e


Text

Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038-0236 Nuclear Business Unit NOVO 61996 LR-N96370 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 LER 311/96-013-00 SALEM GENERATING STATION - UNIT 2 FACILITY OPERATING LICENSE NO. DPR-75 DOC~T NO. 50-311 Gentlemen:

This Licensee Event Report entitled ~Missed Surveillance For Performing Tritium Grab Samples When The Refueling Canal Is Flooded As Required By Technical Specifications" is being submitted pursuant to the requirements of the Code of Federal Regulations 10CFR50. 73 (a) (2) (iv).

Sincerely, fi!:I~~~ow General Manager -

Salem Operations Attachment DVH C Distribution LER File 3.7 9611140312 961106 PDR ADOCK 05000311 S PDR 140016

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95-2168 REV. 6/94

Document Control Desk LR-N96370 NOV o6 1996 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 (311/96-013). The commitments are as follows:

1. The Unit 2 procedure for Filling the Refueling Cavity has been revised to include as a prerequisite that the Chemistry Department has been notified to initiate tritium sampling at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance with Technical Specification 4.11.2.1.1, Table 4.11-2, Notation d. The Unit 1 procedure for Filling the Refueling Cavity will be revised prior to use.
2. This LER will be issued to the Operations Department as required reading by November 19, 1996, to further emphasize the conservative understanding and implementation of Technical Specifications. This has been an ongoing process during the Salem restart effort.

NRCFORM366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMO NO. 3150-0104 (4-95) .. .. EXPIRES 04130/98 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~ ~NUCLEAR (See reverse for required number of REGULATORY COMMISSION, WASHINGTON, DC , AND TO THE PAPERWORK REDUCTION PROJECT (3150-0104), OFACE OF digits/characters for each block) MANAGEMENT AND BUDGET, WASHINGTON, DC 20503.

I FACILITY NAME (1) , ---~~ NUMBER (2) PAGE(3)

SALEM GENERATING STATION UNIT 2 05000311 1 OF 3 TITLE (4)

MISSED SURVEILLANCE FOR PERFORMING TRITIUM GRAB SAMPLES WHEN THE REFUELING CANAL IS FLOODED AS REQUIRED BY TECHNICAL SPECIFICATIONS EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (8)

MONTH DAY YEAR YEAR I SEQUENTIAL NUMBER I REVISION NUMBER MONTH DAY YEAR FACILITY NAME Salem Unit 1 DOCKET NUMBER 05000272 FACILITY NAME DOCKET NUMBER 10 10 96 96 - 013 - 00 11 06 96 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~~in 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 CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TONPRDS TONPRDS SUPPLEMENTAL REPORT EXPECTED (14) EXPECTED MONTH DAY YEAR SUBMISSION IYES (If yes, complete EXPECTED SUBMISSION DATE). XINO DATE (15)

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

At 0102 hours0.00118 days <br />0.0283 hours <br />1.686508e-4 weeks <br />3.8811e-5 months <br /> on July 23, 1996, Operators began to fill the previously empty Refueling Canal. The Refueling Canal was completely filled to the 128'8" elevation by 1046 hours0.0121 days <br />0.291 hours <br />0.00173 weeks <br />3.98003e-4 months <br /> on July 25, 1996. A Tritium Grab Sample was taken at 1420 hours0.0164 days <br />0.394 hours <br />0.00235 weeks <br />5.4031e-4 months <br /> on July 25, 1996. Technical Specification Surveillance Requirement 4.11.2.1.2, which is applicable at all times, requires through Table 4.11-2, Notation d, that "Tritium grab samples shall be taken 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 Refueling Canal is flooded. " A Tritium grab sample was not taken within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of when .flooding began. This was not considered a Technical Specification violation at the time because the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> clock for the Tritium sample was thought to begin after the Refueling Canal was fully flooded to the 128'8" elevation. However, further evaluation by Operations Management determined that this interpretation was not appr~priate.

The cause of this occurrence was determined to be inadequate implementation of Technical Specification requirements. Corrective actions include procedure revisions, and communication of this event to Operations personnel. This event is reportable in accordance with 10 CFR 50.73(a) (2) (i) (B), any condition prohibited by the plant's Technical Specifications.

NRC FORM 366 (4-95)

NRC FORU.366"_.

(4-95)

LICENSEE EVENT REPORT (LER)

U.S. NUCLEAR REGULATORY COMMISSION

. TEXT CONTINUATION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3)

SALEM GENERATING STATION UNIT 2 05000311 YEAR I SE~,i~Al I=~~ 2 OF 3 96 - 013 - 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

PLANT AND SYSTEM IDENTIFICATION Westinghouse - Pressurized Water Reactor Refueling Canal {-/NH}*

  • Energy Industry Identification System (EIIS) codes and component function identifier codes appear as {CC/SS}

CONDITIONS PRIOR TO OCCURRENCE At the time of occurrence, Salem Units 1 and 2 were shutdown and defueled.

DESCRIPTION OF OCCURRENCE At 0102 hours0.00118 days <br />0.0283 hours <br />1.686508e-4 weeks <br />3.8811e-5 months <br /> on July 23, 1996, Operators began to fill the empty Unit 2 Refueling Canal in accordance with S2.0P-SO.SF-0003(Q), Rev. 5,"Filling the Refueling Cavity." The lower Transfer Canal portion of the Refueling Canal was filled to the 93 foot elevation by 0939 hours0.0109 days <br />0.261 hours <br />0.00155 weeks <br />3.572895e-4 months <br /> on July 23, 1996, at which time filling operations were stopped. After the Reactor Vessel Head was removed, filling of the Refueling Canal recommenced at 1630 hours0.0189 days <br />0.453 hours <br />0.0027 weeks <br />6.20215e-4 months <br /> on July 24, 1996. The Refueling Cavity was completely flooded to the 128'10" elevation at 1046 hours0.0121 days <br />0.291 hours <br />0.00173 weeks <br />3.98003e-4 months <br /> on July 25, 1996. A Tritium Grab Sample was taken at 1420 hours0.0164 days <br />0.394 hours <br />0.00235 weeks <br />5.4031e-4 months <br /> on July 25, 1996.

Technical Specification Surveillance Requirement 4.11.2.1.2, which is applicable at all times, requires through Table 4.11-2, Notation d, that "Tritium grab samples shall be taken 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 Refueling Canal is flooded." A Tritium grab sample was not taken until more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the flooding process began.

On July 25, 1996, during a review of the filling process, Operations shift personnel questioned the meaning of the words "when the Refueling Canal is flooded" in Technical Specification Table 4.11-2, Notation d. In particular, it is not clear at what point in the flooding process the requirement for the surveillance begins. The Operators initiated an Action Request in the Corrective Action Program. Operations Management decided that "flooded" meant fully flooded to the 128'8" elevation and thus the tritium grab sample surveillance was performed in time.

During the recent investigation of another event involving the Mode 6 requirement to sample any water in the Refueling Canal for boron conce:r:itration, Operations Management again reviewed this event. The exact wording of Technical Specification 4.11.2.1.2, Table 4.11-2, Notation d, does not appear to require that the 24-hour clock for taking tritium grab samples start at the beginning of the Refueling Canal fill process. However, on October 10, 1996 Operations Management determined that the apparent intent of the Specification does require that tritium grab samples be taken within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of when the Refueling Canal flooding process begins. This was not done on July 24, 1996.

NRC FORM 366A (4-95)

. *r4RC FOtlM au;.* U.S. NUCLEAR REGULATORY COMMISSION (4-95) .

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER i 6) PAGE(3) 05000311 YEAR I SEQUENTIAL NUMBER REVISION NUMBER 3 OF 3 SALEM GENERATING STATION UNIT 2 96 - 013 - 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

CAUSE OF OCCURRENCE The cause of this occurrence was determined to be inadequate implementation of Technical Specification requirements. This resulted in inadequate procedural guidance for filling the Refueling Canal. It is not until the end of procedure S2.0P-SO.SF-0003(Q}, Rev. 6,"Filling the Refueling Cavity," after the Refueling Canal is completely full, that the Operator is instructed to "DIRECT Chemistry Department to initiate tritium s~mpling requirements of Technical Specification 4.11.2.1.1, Table 4.11-2 notation d." This resulted from the common understanding that the Refueling Canal is "flooded" when it is completely filled.

PRIOR SIMILAR OCCURRENCES A review of LERs for Salem Units 1 and 2 over the last two years identified twenty LERs (272/95-004, 272/95-013, 272/95-015, 272/95-019, 272/95-024, 272/95-028, 272/96-003, 272/96-004, 272/96-005, 272/96-008, 272/96-016, 272/96-023, 272/96-024, 311/94-012, 311/95-006, 311/95-008~ 311/96-003, 311/96-007, 311/96-010, and 311/96-011.} that*were due to inadequate implem~ntation of Technical Specification requirements. The corrective actions were specific to the missed surveillance issues addressed in each LER.

The identification of programmatic issues related to the Technical Specification requirement implementation resulted in the initiation of the Technical Specifications Surveillance Improvement Program (TSSIP} described in LER 311/95-008. The TSSIP will provide reasonable assurance that Technical Specification surveillance requirements are adequately proceduralized and will also identify potentially deficient Technical Specification Limiting Conditions for Operation.

SAFETY CONSEQUENCES AND IMPLICATIONS At the time of this event, the reactor was defueled with the refueling cavity being filled. Tritium Grab Sample analysis performed prior to and after cavity fill were all below the Lower Limit of Detection (LLD} of lXl0- 6

  • Therefore, this event did not affect the health or safety of the general public.

CORRECTIVE ACTIONS

1. The Unit 2 procedure for Filling the Refueling Cavity has been revised to include as a prerequisite that the Chemistry Department has been notified to initiate tritium sampling at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance with Technical Specification 4.11.2.1.1, Table 4.11-2, Notation d. The Unit 1 procedure for Filling the Refueling Cavity will be revised prior to use.
2. This LER will be issued to the Operations Department as required reading by November 19, 1996, to further emphasize the conservative understanding and implementation of Technical Specifications. This has been an ongoing process during the Salem restart effort.

NRC FORM 366A (4-95)

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