ML18106A879

LER 96-006-01:on 960717,determined That non-radioactive Liquid Basin Radwaste Monitor Inoperable During Low Head Conditions.Caused by Inadequate Design Change Package.Design Change 1EC3663-01 Has Been Installed.With 980916 Ltr

ML18106A879
Person / Time
Site:	Salem
Issue date:	09/16/1998
From:	Bakken A, Duca P Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-96-006-01, LER-96-6-1, LR-N980443, NUDOCS 9809240309
Download: ML18106A879 (6)

Text

OPS~G *

• Public *Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038-0236 Nuclear Business Unit SEP 16 1998 LR-N980443 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

. SUPPLEMENTAL LER 311/96-006-01 SALEM GENERATING STATION - UNIT 2 FACILITY OPERATING LICENSE NO. DPR-75 DOCKET NO. 50-311 Gentlemen:

This Supplemental Licensee Event Report entitled "lnciperability of Non-Radioactive Liquid Basin Radwaste Monitor During Low Head Conditions " .is being submitted pursuant to the requirements of the Code of Federal Regulations ***10CFR50.73 (a)(2)(i) (B)***.

Sincerely, General Manager Salem Operations Attachment PJD/

c Distribution LER File 3.7 9809240309 980916 PDR ADOCK 05000311 S PDR The power is in your hands.

95*2168 REV..6/94

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NRC FORM366 U.S. NUCLEAR REGULA COMMISSION APPROVED B B NO. 3150-0104 EXPIRES 06/30/2001 (6-1998) Estimated burden r response to comply with this mandatory information collection request: 50 hrs. Refeorted lessons learned are incorporated into LICENSEE EVENT REPORT (LER) the licensing process and ed back to industry. Forward comments reiarding burden estimate to the Records Management Branch U.. Nuclear R~ulatory Commission, Washington, DC 20555-00 1, and to s;-a F33),

(See reverse for required number of the Paperwork eduction Project (3150-0104), Office of Management and digits/characters for ~ach block) Budr,et, Washin~ton, DC 20503. If an information collection does not disp ay a current y valid OMB control number, the NRG may not conduct or sponsor, and a person is not required to respond to, the information collection.

IFACILITY NAME (I) IDDCKK<NUMBER "' PAGE(J)

SALEM UNIT 2 05000311 1 OF 5 TITLE(4)

Inoperability of Non-Radioactive Liquid Basin Radwaste Monitor During Low Head Conditions EVENT DA TE (5) LER :'llD-IBER (6) REPORT DA TE (7) OTHER FACILITIES INVOLVED (8)

MONTH DAY YEAR YEAR I SEQUENTIAL NUMBER IREVISION NUMBER MONTH DAY YEAR FACILITY :-IA~IE Salem Unit 1 DOCKET NUMBER 05000272 FACILITY NAME DOCKET NUMBER 07 17 96 96 -006 - 01 9 16 98 05000 n*

OPERATING MODE(9) N 20.2201(b) 20.2203(a)(I) 20.2203(a)(2)(v) x THJ4' ll!F.PORT 14' 4'1Jl~MHTF.n PJTD .. JJANT TO THF. R F.OfJJRF.MF.NTS OF 10 CFR 50.73(a)(2)(i)

50. 73(a)(2)(ii)

Wh ,_,,_ '"~ nr mnn>\ {11\

50. 73(a)(2)(viii)

POWER 20.2203(a)(3)(i) 50. 73(a)(2)(x)

LEVEL(IO) 000 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

(j 20.2203(a)(2)(iii) 20.2203(a)(2)(iv) 50.36(c)( I) 50.36(c)(2) 50.73(a)(2)(v) 50.73(a)(2)(vii)

Specify in Abstract below or in NRC Form 366A I

LICENSEE CONTACT FOR THIS LER (12)

NAME TELEPHONE NUMBER (Include Area Code)

Philio J. Duca Jr. , Salem Licensino Enoineer (609) 339-2381 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

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COMPONE REPORTABLE REPORTABLE CAUSE SYSTEM NT MANUFACTURER TO EP!X  !:i CAUSE SYSTEM COMPONENT MANUFACTURER TO EPIX

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~

4'J!PPJFMFNTAI Rl<PODT * "~* .*n {Id\ MONTH DAY YEAR EXPECTED

'YES (If yes, complete EXPECTED SUBMISSION DATE). Ix I No SUBMISSION DATE (IS)

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

On July 17, 1996, an engineering review determined that sample flow to the non-radioactive liquid radwaste monitor (instrument 2R37) was not adequate in certain conditions to meet the monitoring requirements of Salem Unit 2 Technical Specifications, Table 3.3-12. Contrary to the requirements of Action 31 of Table 3.3-12, compensatory actions had not been taken because the low sample flow condition was unrecognized. All discharges conducted prior to having declared 2R37 inoperable for software concerns on November 28, 1995 were affected by this design condition.

The cause of this occurrence was an inadequate design change package.

Corrective actions included a design change, continuation of compensatory actions until the monitor was returned to an operable status, and a review of other monitors for similar problems. Programmatic weaknesses apparent in the inadequate design change are already addressed under PSE&G's present modification program.

Conditions that could result in contaminated water in the discharge would be considered a rare occasion and would have to take place concurrent with equipment failure. Additionally radiation monitors (steam generator blowdown monitors) would detect such radiation and isolate the condition.

Therefore, it is highly unlikely that the health and safety of the public was ever affected.

This event is reportable in accordance with 10 CFR 50. 73 (a) (2) (i) (B), any operation or condition prohibited by the plant's Technical Specifications.

NRC FORM 366A U.S. '.'it:CLEAR REGULATORY COMMISSION

' . (6-1998)

• • LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION DOCKET(2)

FACILITY NA'.\IE (I) NUMBER(2) LER NUMBER (6) PAGE (3)

YEAR I SEQUENTIAL NUMBER IREVISION NUMBER SALEM UNIT 2 05000311 96 0 0 6 01 2 OF 5 TEXT (If more space is required, use additional copies of!v'RC Form 366A) (17)

PLANT AND SYSTEM IDENTIFICATION Westinghouse - Pressurized Water Reactor Radiation Monitor System/Monitor {IL/MON}*

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

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

DESCRIPTION OF OCCURRENCE On July 17, 1996, an engineering review determined that sample flow to the non-radioactive liquid radwaste monitor (instrument 2R37) was not adeqqate in certain.conditions to meet the monitoring requirements of Salem Unit 1 Technical Specifications, Table 3.3-12. Contrary to the requirements of Action 31 of Table 3.3-12, compensatory actions had not been taken because the low sample flow condition was unrecognized. The most recent discharge that was affected by this unrecognized condition occurred on November 22, 1995. On November 28, 1995, 2R37 was declared inoperable for software concerns (a condition not connected to the flow problem) and compensatory actions were initiated and continued until 2R37 was restored to operability.

All discharges conducted prior to having declared 2R37 inoperable on November 28, 1995 were affected by this design condition.

The non-radwaste basin provides a potential radiological release path for leakage from the primary system to the secondary system. An off-line sampler I

(2R37) is provided to continu6usly monitor the discharge from the non-radwaste basin. The non-radwaste basin is pumped to the Delaware River via the circulating water system.

Based on an observation of no flow through the 2R37 radiation monitor sample line during a discharge of liquid waste, maintenance was performed to clear suspected blockage. Maintenance personnel did not note any blockage of the NRC FORM 366A (6-1998)

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NRC FORM 366A (6-1998)

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

TEXT CONTINUATION I

DOCKET(2)

FACILITY NAME (I) NUMBER(2) LER NUMBER (6) PAGE (3)

YEAR ISEQUENTIAL NUMBER IREVISION NUMBER SALEM UNIT 2 05000311 96 0 0 6 01 3 OF 5 TEXT (If more space is required. use additional copies of.VRC Form 366A) (17) sample line. Subsequent troubleshooting identified that the flow through the sample line was sensitive to system head and that under conditions of low tide with only one discharge pump in operation, there would be no flow past the 2R37 monitor.

CAUSE OF OCCURRENCE The cause of this occurrence was the design o~ the non-radwaste_ discharge line not providing adequate back pressure to provide flow to the 2R37 radiation monitor or to the discharge flow permissive pressure ~witch. A * .--

design change (DCP lEC-1525) installed in the mid-1980's relocated non-radwaste effluent piping and the 2R37. The piping re-design under lEC-1525 apparently did not consider the conditions required to ensure flow through 2R37. The basis of the piping design was not recorded in the DCP. No design analysis section could be found. Additionally the packages do not contain post modification tests verifying flow through 2R37 during non-radwaste discharges. The DCP program at the time did not require a concise de~ign - 0 basis description nor post modification testing of all aspects of the - _

modification (such as ensuring sample flows through 2R37). - Consequently> t'l:-i~'

justification or causes of the omissions described above could not be ascertained.

PRIOR SIMILAR OCCURRENCES Design Change Package lEC-1525 was issued 12/05/84. Salem Unit 1 and Unit 2 1983 and 1984 LERs were searched and one similar occurrence was noted.

Salem Unit 1 LER 83-006/03L, dated 2/23/83 discussed inoperable emergency diesel generators. During a refueling outage, a design change requese follow-up identified that non-seismically qualified components had been installed in the Class lE control power DC feeds to the emergency diesel generators.

Investigation of the problem revealed that the occurrence involved an oversight of seismic requirements in the design of the control power modification.

Personnel involved in the design of the modification reviewed the FSAR design bases and appropriate seismic standards. The occurrence was deemed to be an isolated event and no further action was deemed necessary.

NRC FORM 366A (6-1998)

NRC FOR'.\I 366.-\ t:.S. :\TCLEAR R Gl"LATORY CO'.\HllSSION (6-1998)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION DOCKET(2)

FACILITY :\A'.\IE (I)  :\'DIBER(2) LER :\liMBER (6) PAGE (3)

YEAR I SEQUENTIAL NUMBER I REVISION NUMBER SALEM UNIT 2 05000311 96 0 0 6 01 4 OF 5 TEXT (If more space is required. use addi1io~al copies of.\RC Form 366AJ (17)

SAFETY CONSEQUENCES AND IMPLICATIONS The consequences for the inadequate sample flow are that the non-radwaste basin liquid contents may have not been fully monitored prior to discharge for all discharges conducted before November 28, 1995. However, the sole potentially contaminated fluid directed to the non-radwaste basin is steam generator blowdown. Steam generator blowdown is not likely to be contaminated unless tube leaks are present. Salem Technical Specifications provide limits for tube leakage and the radiation monitors for steam generator blowdown have the capability to isolate the blowdown line if radiation levels are sufficiently high. Therefore, the probability of having contaminated steam generator blowdown water in the basin is very low. Monthly gross activity monitoring of the basin liquid effluent contents confirm that activity levels are below the lower limit of detectability.

It is highly unlikely that the health and safety of the public was ever affected.

CORRECTIVE ACTIONS

1. A design change (1EC3663-01) has been installed. The change adds a pressure regulating valve downstream of 2R37 to provide sufficient backpressure to ensure adequate flow through the radiation monitor

2. Compensatory actions for 2R37 inoperability, already in place at the time of the discovery of the low flow condition, were continued until 2R37 was restored to operability subsequent to implementation of 1EC3663-01.

3. A hydraulic comparison was made for other plant monitors under static conditions. These monitors were 2Rl3s (Service Water Containment Fan Coil Unit Effluent), 2Rl9s (Steam Generator Blowdown), 1Rl8 (Unit 1 Liquid Radwaste Effluent) and 2Rl8 (Unit 2 Liquid Radwaste Effluent) .

The comparison showed that adequate flow would exist through these monitors.

NRC FORM ~66A (6-1998)

NRC FOR'.\ol 366A u.S. NUCLEAR REGVLA TORY COM:\llSSIO:'-i (6-1998)

'i

• ~ LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION DOCKET(2)

FACILITY '.'IA'.\olE (1) NUMBER(2) LER NUMBER (6) PAGE(J)

YEAR I SEQUENTIAL NUMBER IREVISION NUMBER SALEM UNIT 2 05000311 96 0 0 6 01 5 OF 5 TEXT (If more space is required. use additional copies o/1VRC Form 366A) (17)

4. PSE&G's modification process has changed since the mid-1980's. The programmatic weaknesses apparent in DCP lEC-1525 are addressed under PSE&G's present modification program. The program's current attributes include:

• An analysis section supporting the design basis.

• A strict interdisciplinary review with respect to the conformance/adherence to technical and regulatory commitments.

• A review to ensure the proposed modification will function properly. ,;

• Acceptance criteria for testing and maintenance (developed and specified during the design change package preparation stage of the modification) .

• Post modification testing under specified limiting conditions.

NRC FORM 366A (6-1998)