ML18102B468

LER 97-005-00:on 970625,radioactive Liquid Effluent Samples Were Not Analyzed within Required Surveillance Interval. Caused by Incorrect Interpretation of TS Sr.Training Will Be Provided to Chemistry Supervisors.W/970725 Ltr

ML18102B468
Person / Time
Site:	Salem
Issue date:	07/25/1997
From:	Garchow D, Bernard Thomas Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-97-005-02, LER-97-5-2, LR-N970463, NUDOCS 9708040138
Download: ML18102B468 (5)

Text

• OPS~G Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge. New Jersey 08038-0236 Nuclear Business Unit JUL 2 5 1997 LR-N970463 U. S. Nuclear Regulatory c;,ommission Document Control Desk Washington, DC 20555 LER 272/97-005-00 SALEM GENERATING STATION - UNIT 1 FACILITY OPERATING LICENSE NO. DPR-70 DOCKET NO. 50-272 Gentlemen:

This Licensee Event Report entitled "Radioactive Liquid Effluent Samples Not Analyzed within Required Surveillance Interval" is being submitted pursuant to the requirements of the Code of Federal Regulations 10CFR50. 73 (a) (2) (i) (B).

General Manager -

Salem Operations Attachment I

/

BJT C Distribution LER File 3.7 9708040138 970725 PDR - ADOCK 05000272 S PDR I111111111111111111111111111111111111111

• Iii Iii 5 6 2 "

• The: pmuT is in your hands.

95-2168 REV. 6/94

NRC FORM 366 (4-95)

U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER).

APPROVED BY OMB NO. 3150-0104 EXPIRES 04/30/98 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS MANDATORY INFORMATION COLLECTION REQUEST: 50.0 HRS.

REPORTED LESSONS LEARNED ARE INCORPORATED INTO THE LICENSING PROCESS AND FED BACK TO INDUSTRY. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE INFORMATION AND RECORDS MANAGEMENT. BRANCH (T~ F33). U.S. NUCLEAR (See reverse for required number of REGULATORY COMMISSION, WASHINGTON, DC 20555--0001, AND TO THE PAPERWORK REDUCTION PROJECT (3150--0104), OFFICE OF digits/characters for each block) MANAGEMENT AND BUDGET, WASHINGTON, DC 20503.

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

SALEM GENERATING STATION, UNIT 1 05000272 1 OF4 TITLE (4)

Radioactive Liquid Effluent Samples Not Analyzed Within Required Surveillance Interval  ;,

EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (8)

FACILITY NAME DOCKET NUMBER MONTH DAY YEAR YEAR I SEQUENTIAL NUMBER I REVISION NUMBER MONTH DAY YEAR SALEM UNIT 2 05000311 FACILITY NAME DOCKET NUMBER 06 25 97 97 -- 005 -- 00 07 25 97 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 0 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 11*

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) Spec~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)

Brian J. Thomas, Licensing Engineer 609-339-2022 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TO NPRDS TO NPRDS SUPPLEMENTAL REPORT EXPECTED (14) EXPECTED MONTH DAY YEAR

/YES SUBMISSION (If yes, complete EXPECTED SUBMISSION DATE). XINO DATE (15)

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

During the review of a Technical Specification (TS) surveillance work order on June 26, 1997, for the performance of gross alpha analysis on a composite liquid sample in accordance with TS 3.11.1.1 Table 4.11-1, Operations Department personnel questioned Chemistry personnel on whether the completion date of the analysis was meeting the surveillance requirements of the TS. Subsequently, a determination was made that the required surveillance interval for the analysis of the composite sample was not being*satisfied.

The cause of this event is attributed to an incorrect interpretation of the TS surveillance requirements by Chemistry personnel. A review of similar TS surveillances was performed which identified a similar reportable occurrence for quarterly liquid composite sampling analysis for Sr-89, Sr-90 and Fe-55, monthly gaseous composite sample analysis for gross alpha and quarterly gaseous composite sample analysis for Sr-89, and Sr-90. Surveillance testing work order compl_etion dates will be or have been revised to ensure compliance with the TS surveillance interval and training will be provided to the Chemistry Supervisors.

This event is being reported 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)

NRG fORM 366A (4-95) *

• LICENSEE EVENT REPORT (LER)

U.S. NUCLEAR REGULATORY COMMISSION TEXT CONTINUATION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3) 05000272 YEAR I SEQUENTIAL NUMBER IREVISION NUMBER 2 OF 4 SALEM GENERATING STATION, UNIT 1 97 -- 005 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

PLANT AND SYSTEM IDENTIFICATION Westinghouse - Pressurized Water Reactor Liquid Waste System (LWS) {WO/-}*

Gaseous Waste System (WE/-}

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

CONDITIONS PRIOR TO OCCURRENCE At the time of occurrence Salem Unit 1 was defueled and Salem Unit 2 was in Mode 4.

DESCRIPTION OF OCCURRENCE During the review of a Technical Specification (TS) surveillance work order on June 26, 1997, for the performance of gross alpha analysis on a composite liquid sample in accordance with Technical Specification 3.11.1.1 Table 4.11-1, Operations Department personnel questioned Chemistry personnel on whether the completion date of the liquid composite analysis was meeting the surveillance requirements of the TS.

The Unit 2 liquid composite sample for gross alpha analysis was completed on April 30, 1997; however, the sample analysis results were not completed until June 11, 1997. The composite liquid sample has a monthly surveillance frequency. With the 25% surveillance interval extension allowed by TS 4.0.2, the required due date for the analysis was June 7, 1997. This particular sample for gross alpha analysis is sent to an outside vendor for performance of the analysis r~quired by the TS. Chemistry personnel had interpreted the monthly surveillance requirement of'Technical Specification 3.11.1.1, Table 4.11-1 to mean as long as analysis results of the composite samples were received from the outside vendor within 31 days of the previous analysis results, the surveillance was met. In addition, due to this interpretation by Chemistry personnel, the samples were not being sent to the vendor in an expeditious manner to ensure that the results of the analysis were received by PSE&G within 31 days of the completion of liquid composite sampling.

The TS interval was clarified to Chemistry personnel that the analysis of the composite sample had to be completed within 31 days of the completion of the composite sampling. A review of surveillance testing for liquid composite samples for Salem Unit 1 was performed which determined that analysis of the Unit 1 samples also did not comply with the TS required monthly surveillance interval.

NRC FORM 366A (4-95)

NRC fORM 3{)6A (4-95)

• LICENSEE EVENT REPORT (LER)

U.S. NUCLEAR REGULATORY COMMISSION TEXT CONTINUATION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3) 05000272 YEAR I SEQUENTIAL NUMBER IREVISION

. NUMBER 3 OF 4 SALEM GENERATING STATION, UNIT 1 97 -- 005 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

DESCRIPTION OF OCCURRENCE (cont'd)

A review of other TS required surveillances was performed by Chemistry personnel to determine if other sampling requiring analysis by an outside vendor was complying with the required surveillance testing interval. This review identified that a similar problem existed with the quarterly gaseous and liquid composite sample analysis for Sr-89 and Sr-90 required by TS 3.11.2.1 Table 4.11-2, quarterly gaseous sample analysis for gross alpha, and quarterly liquid composite sample analysis for Fe-55 for both Units 1 and 2.

CAUSE OF OCCURRENCE The cause of this event is attributed an incorrect interpretation of the Technical Specification surveillance requirements by Chemistry personnel. In addition, the samples were not being sent to the vendor in an expeditious manner to ensure that the results of the analysis were received by PSE&G within 31 days of the completion of liquid composite sampling.

PRIOR SIMILAR OCCURRENCES A review of LERs for Salem Units 1 and 2 for the past two years identified four prior similar occurrences associated with incorrect interpretations of surveillance testing requirements.

LER 272/95-004-00 identified that surveillance requirement 4.6.1.5 was not being complied with for both Salem Units regarding the method to determine primary containment air temperature. The cause was attributed to an interpretative oversight of the verbatim requirement to use five locations to determine the average air temperature. The corrective actions associated with this event included a review of the importance of procedure adequacy to ensure TS compliance with the appropriate plant groups.

LER 272/96-023-00 identified the surveillance for the Main Steam Isolation Valves was not being performed prior to entry into Mode 3 as required by the TS.

The cause was attributed to a less than adequate review of the original TS and a subsequent inadequate interpretation of TS 4.7.1.5. The corrective actions associated with the event included a required reading of the LER by the Operations Department to further emphasize the conservative understanding and implementation of TS.

LER 311/96-002-00 identified that the Waste Gas Decay Tank oxygen concentration had exceeded the TS limit. The cause of the occurrence was determined to be poor wording and interpretation of the TS. The corrective actions associated with this event included a review by Operations Management to the Operating Crews emphasizing the need to comply with the intent and the exact wording of the TS.

NRC FORM 366A (4-95)

) NRC (4-95)

.~ORM 3f;6A

• LICENSEE EVENT REPORT (LER)

U.S. NUCLEAR REGULATORY COMMISSION TEXT CONTINUATION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3) 05000272 YEAR I SEQUENTIAL NUMBER I REVISION NUMBER 4 OF 4 SALEM GENERATING STATION, UNIT 1 97 -- 005 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

PRIOR SIMILAR OCCURRENCES (cont'd)

LER 311/96-013-00 identified a missed surveillance for performing Tritium grab samples when the refueling canal is flooded as required by TS. The cause of this occurrence was determined to be inadequate implementation of TS requirements as result of the interpretation of when the Refueling Canal was determined to be flooded." The corrective actions associated with this event included required reading by the Operations Department of this LER to further emphasize the conservative understanding and implementation of TS.

SAFETY CONSEQUENCES AND IMPLICATIONS Although the late analysis of the composite samples would prevent timely notification to the NRC for releases that exceeded the Technical Specification limits, the analyzed composite samples demonstrate that the releases have been within the limits specified in Technical Specification Table 4.11-1 and 4.11-2.

Therefore, there was no impact to the health and safety of the public.

CORRECTIVE ACTIONS

1. The completion dates for the surveillance work orders to perform the analysis of the composite liquid and gaseous release sampling in accordance with Technical Specification Tables 4.11-1 and 4.11-2 have.been adjusted for the monthly surveillances or will be adjusted for the quarterly surveillances, prior to performance of the next surveillance, to ensure that the analyses are completed within the required surveillance interval.

2. Training will be provided to Chemistry Supervisors on the importance of ensuring that sampling and analysis activities associated with Technical Specification surveillances are completed within the proper surveillance test interval. This training will be completed by August 1, 1997.

3. Chemistry is currently evaluating the method of transporting the samples to the vendor and will complete this evaluation by August 16, 1997.

NRC FORM 366A (4-95)