ML18101B126

LER 95-028-00:on 950920,effective Leakage Monitoring Program Did Not Meet TS 6.8.4a Requirements Due to Mgt/Qa Deficiency.Consolidated Program Under Single Organization to Assure Plant Design Basis satisfied.W/951201 Ltr

ML18101B126
Person / Time
Site:	Salem
Issue date:	12/01/1995
From:	ODONNELL P, WARREN C C Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-95-028-01, LER-95-28-1, LR-N95226, NUDOCS 9512110188
Download: ML18101B126 (6)

Text

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• Public Service Electric and Gas Company P.O. Box New Jersey 08038-0236 Nuclear Business Unit LR-N95226 U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Att.: Document Control Desk SALEM GENERATING STATION LICENSE No.: DPR-70 and DPR-75 DOCKET No. 50-272 and 50-311 UNIT Nos. 1 and 2 LICENSEE EVENT REPORT No. 95-028-00 This Licensee Event Report is being voluntarily submitted pursuant to the requirements of Code of Federal Regulation 10CFR50.73.

SORC Mtg. No.: 95-145 C Distribution LER file 3.7 9512110188 951201 PDR ADOCK 05000272 S PDR Sincerely, General Manager -Salem Operations 95-2168 REV. 6/94

.. . I NRC FORM 366 U.S. N EAR REGULA TORY COM.MISSION APPROVED BY OMB NO. 3150-0104 14-95) EXPIRES 04/30/98 ESTIMATED BURDEN PER RESPONSE TO COMPLY Willi TlilS MANDATORY INFORMATION COLLECTION REQUEST: 50.0 HRS. LICENSEE REPORT (LER) REPORTED LESSONS LEARNED ARE IN CORPORA TED INTO TliE EVENT LICENSING PROCESS AND FED BACK TO INDUSTRY.

FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE (See reverse for required number of INFORMATION AND RECORDS MANAGEMENT BRANCH IT-6 F331, digits/characters for each block) U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555-0001, AND TO TliE PAPERWORK REDUCTION PROJECT FACILITY NAME 111 DOCKET NUMBER (21 PAGEl31 Salem Generating station -Unit 1 05000272 1 OF 4 TITLE 141 Lack of Effective Leakage Monitoring Program Required by TS 6.8.4a EVENT DATE (51 LER NUMBER (61 REPORT DATE 171 OTHER FACILITIES INVOLVED 181 I I REVISION FACILITY NAME DOCKET NUMBER MONTH DAY YEAR yEAR SEQUENTIAL

• MONTH DAY YEAR NUMBER NUMBER Salem Generating Station -Unit 2 05000311 FACILITY NAME DOCKET NUMBER 09 20 95 95 --028 --000 12 01 95 OPERATING

• THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check one or more) 1111 MODE 191 20.2201(b) 20.2203(a)(2)(v) 50.73(a)(2)(i) 50.73(a)(2)(viii)

I POWER I I 20.2203(a)(1) 20.2203(a)(3)(i) 50.731a)(2)(ii) 50.73(a)(2)(x)

LEVEL 1101 0 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) x OTHER 20.2203(a)(2)(iii) 50.36(c)(1) 50.73(a)(2)(v)

Voluntary LER 2203(a)(2)(iv) 50.36(c)(2) 50.73(a)(2)(vii)

LICENSEE CONTACT FOR THIS LER 1121 NAME TELEPHONE NUMBER !Include Aree Codel Philip.O'Donnell, NSSS System Engineering 609 -339 -2041 Supervisor

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CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TO NPRDS TO NPRDS ::::::::::::::::::::::::::::

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SUPPLEMENTAL REPORT EXPECTED 114) EXPECTED MONTH DAY YEAR 'YES xjNo SUBMISSION (If yes, complete EXPECTED SUBMISSION DATE). DATE (15) ABSTRACT (Limit to* 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) 116) During system readiness review of the safety injection system, a question was raised relative to compliance with Technical Specification (TS) 6.8.4a. TS 6.8.4a requires a program to monitor and reduce leakage from those portions of systems outside containment that could contain highly radioactive fluids during a postulated accident.

It was determined that elements of this leakage monitoring program exist, but they are presently not controlled as an integrated program. Leak rate data is not compiled for comparison with the licensing basis leak rate. The cause of this event has been attributed to Management/QA deficiency.

Corrective actions taken include consolidation of the program under a single organization and enhancements to assure plant design basis is satisfied.

.. NRC FORM 366 14*95 * * .. NRC FORM 366A 14-95) U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER) TEXT CONTINUATION FACILITY NAME 111 DOCKET Salem Generating station -Unit 1 05000272 TEXT (If more space is required, use additional copies of NRC Form 366AJ 1171 PLANT AND SYSTEM IDENTIFICATION Westinghouse

-Pressurized Water Reactor Chemical and Volume Control (CVC) {CB} Residual Heat Removal (RHR) {BP} Containment Spray (CS) {BE} Safety Injection (SJ) {BQ} Sampling (SS) {IP} Radioactive Liquid (WL) {WD} Waste Gas (WG) {WE} LER NUMBER 161 YEAR I SEQUENTIAL I REVISION NUMBER NUMBER 95 --028 --000 PAGE 131 2 OF 4

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

IDENTIFICATION OF OCCURRENCE Discovery Date: September 20, 1995 Report Date: December 1, 1995 CONDITIONS PRIOR TO OCCURRENCE Unit 1 2 Mode Defueled 5 DESCRIPTION OF OCCURRENCE

% Reactor Power 0 0 On August 31, 1995, during a system readiness review* meeting, the implementation of Technical Specification (TS) 6.8.4a was questioned.

The TS states, in part: " a. Primary Coolant Sources Outside Containment A program to reduce leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to as low as practical levels. The systems include (recirculation spray, safety injection, chemical and volume control, gas stripper, recombiners, ... ).The program shall include the following:

• (i) Preventive maintenance and periodic visual inspection requirements, and .(ii) Integrated leak test requirements for each system at refueling cycle :intervals or less." NRC FORM 366A 14*95)

NRC FORM 366A 14-951 U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER) TEXT CONTINUATION FACILITY NAME 111 DOCKET LER NUMBER 161 YEAR I SEQUENTIAL I REVISION NUMBER NUMBER Salem Generating Station -Unit 1 05000272 95 --028 --000 TEXT (If more space is required, use additional copies of NRC Form 366AJ I 171 PAGE 131 3 OF 4 An investigation into this concern revealed that these requirements were incorporated in the TS in response to NUREG-0578, "TMI Lessons Learned." The TS 6.8.4a requirements for "preventive maintenance and periodic visual inspection requirements" are in place, but they are not controlled as a single program. Daily leak reduction activities are performed by the Operations Department.

System leak tests have been performed after every refueling outage by the In-Service Testing organization.

• However, it has been determined that these leak reduction activities do riot comprise a well-defined program for the following reasons: 1. There is no specific organization that monitors and controls the leak reduction program and ensures that is kept in compliance with TS requirements.

2. The once-per-refueling cycle system leak test procedures do not reference TS 6.8.4a. The daily leak reduction activities are performed to reduce liquid radwaste, not to comply with TS 6.8.4a. 3. The leak monitoring program does not compare leak rate data with the licensing basis leak rate (0.008gpm) assumed in the UFSAR. 4. The program does not require the eve, SI and RHR pumps to be in operation to make observations on pump seal leakage. APPARENT CAUSE OF OCCURRENCE The cause of this event has been attributed to management/QA deficiency,.

in that no one individual or organization was a,ssigned lead responsibility for compliance with the administrative requirements of TS 6.8.4a.

• PRIOR SIMILAR OCCURRENCES Previous similar occurrences of failure to meet Technical Specification Section 6 administrative requirements include LER 272/94-016 regarding inadequate control room staffing and LER 272/91-011 regarding an unlocked/unguarded door to a high radiation area. SAFETY SIGNIFICANCE The intent of TS 6.8.4a is to assure that leakage from the Eees cold leg recirculation loop into the auxiliary building during a postulated design basis accident would not result in violations of GDC 19 and lOCFRlOO limits. One known example of safety significant leak from systems covered by this TS has been positive displacement charging pump (PDP) packing leaks. The leak rate for the operating PDP has been greater than the leak rate assumed in the UFSAR. LER 272/95-027 issued on 11/25/95 provides further information on this issue. This program deficiency resulted in a missed opportunity to identify and minimize the PDP packing leaks. '* NRC FORM 366A (4-951

' NRC FORM 366A 14-96) U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER) TEXT CONTINUATION FACILITY NAME 111 DOCKET LER NUMBER 161 05000272 YEAR I SEQUENTIAL I REVISION NUMBER NUMBER Salem Generating Station -Unit 1 95 --028 --000 TEXT (If more space is required, use additional copies of NRG Form 366AJ 1171 CORRECTIVE ACTIONS PAGE 131 4 OF 4 The TMI lessons learned programs of TS 6.8.4 will be evaluated to ensure they are properly implemented and meet the intent of Technical Specifications.

Operations department will take lead responsibility for the TS 6.8.4a leak reduction program and will ensure the program is improved as required to meet TS 6.8.4a. This action will be completed prior to the units entering mode 4. NRC

• Attachment A The following items represent commitments that Public Service Electric and Gas (PSE&G) made to the Nuclear regulatory Commission (NRC) relative to this LER (95-028).

The commitment is a follows: 1. The TMI lessons learned programs of TS 6.8.4a will-be evaluated to ensure they are properly implemented and meet the intent of Technical Specifications.

Operations department will take lead responsibility for the TS 6.8.4a leak reduction program and will ensure the program is improved as required to meet TS This action will be completed prior to the units entering mode 4.