ML18106A606

Corrected LER 98-004-00:on 980302,failure to Comply W/Tss 4.11.1.1.2 & 3.3.3.8 Was Noted.Caused by Organizational Deficiency.Steps Have Been Taken to Correctly Document Safety Factors.Corrects Prior Similar Occurrences

ML18106A606
Person / Time
Site:	Salem
Issue date:	04/01/1998
From:	Knieriem B Public Service Enterprise Group
To:
Shared Package
ML18106A604	List: ML18106A603 ML18106A606
References
LER-98-004-02, LER-98-4-2, NUDOCS 9805210372
Download: ML18106A606 (5)

Text

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150-0104 (4-95) EXPIRES 04/30/98 LICENSEE EVENT REPORT (LER) 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 (See reverse for required number of BACK TO INDUSTRY.

FORWARD COMMENTS

• REGARDING BURDEN ESTIMATE TO THE INFORMATION AND RECORDS MANAGEMENT BRANCH digits/characters for each block) IT-6 F33J. U.S. NUCLEAR REGULATORY COMMISSION.

WASHINGTON, DC 20555-0001, AND TO THE PAPERWORK REDUCTION PROJECT (3150-0104), OFFICE OF MANAGEMENT AND BUDGET, WASHINGTON, DC 20503. FACILITY NAME 11 I DOCKET NUMBER 121 PAGE 131 SALEM GENERATING STATION, UNIT 1 05000272 1 OF 5 TITLE 141 Failure To Perform Radioactive Effluent Concentration Surveillance And Effluent Monitoring Instrument Channel Setpoint Determinations In Accordance With Technical Specifications EVENT DATE (5) LER NUMBER 16) REPORT DATE 17) OTHER FACILITIES INVOLVED 18) I FACILITY NAME DOCKET NUMBER MONTH DAY YEAR YEAR SEQUENTIAL I REVISION MONTH DAY YEAR NUMBER NUMBER Salem Unit 2 05000311 03 02 98 98 004 00 04 01 98 FACILITY NAME DOCKET NUMBER ----OPERATING 4 THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check one or more) 111) MODE (9) 20.2201(b) 20.2203(a)(2)(v) x 50. 73(a)(2llil

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

POWER 000 20.2203(a)( 1 l 20.2203(a)(3)(i)

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

50. 73(a)(2)(x)

LEVEL (10) 20.2203(a)(2llil 20.2203(a)(3)1iil

50. 73(a)(2)(iiil 73.71 -20.22031all2lliil 20.2203(a)(4)

50. 73(a)(2)(iv)

OTHER 20.2203(a)(2)(iii) 50.36(cll 1 l 50. 731all2llvl Specify in Abstract below or in NRC Form 366A 20.2203(a)(2)(iv) 50.36(c)(2)

50. 73(a)(2)(vii)

LICENSEE CONTACT FOR THIS LER 1121 NAME TELEPHONE NUMBER (Include Area Code) Brooke Knieriem, Licensing Engineer (609) 339-1782 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT 113) CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE I CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TO NPRDS TO NPRDS SUPPLEMENTAL REPORT EXPECTED 114) EXPECTED MONTH DAY YEAR IYES INO SUBMISSION (If yes, complete EXPECTED SUBMISSION DATE). DATE (15) ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) (16) This LER documents the failure of Salem Units 1 and 2 to comply with the requirements of Technical Specifications (TS) 4.11.1.1.2, Radioactive Effluents, and TS 3. 3. 3. 8, Radioactive Liquid Effluent Monitoring and Instrumentation.

TS 4 .11.1.1. 2 requires that the results of radioactivity analyses be used in accordance with the Off site Dose Calculation Manual (ODCM) to* assure that the release concentrations are maintained within TS limits. Salem TS 3.3.3.8 requires that radioactive effluent monitoring instrumentation channel alarm and trip setpoints be determined in accordance with the ODCM. Contrary to these requirements, release rate calculations and radioactive effluent monitoring channel setpoints were identified that employed a Safety Factor different from that specified by the ODCM. This event is under 10CFRS0.73(a)

(2) (i) (B), any operation or condition prohibited by the plant's TS. Although instances were identified in which the Safety Factor used was less conservative than the Safety Factor in the ODCM, no instances were identified in which TS concentration limits for release were exceeded.

The apparent cause of *this event was an organizational deficiency in the implementation of the Radioactive Effluents/ODCM program. A contributing factor was a lack of understanding by station personnel of the role of the ODCM in the licensing basis. Corrective actions were taken to correctly document the Safety Factor in the ODCM and to correct Safety Factor discrepancies between the ODCM, the implementing procedure, and the Radioactive Effluents TS (RETS) software.

Other corrective actions will be taken to address programmatic and issues identified as a result of this event. 80512 S PDR NRC FORM 366A (4-95) U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER) TEXT CONTINUATION FACILITY NAME 11 l DOCKET NUMBER (21 SALEM UNIT 1 05000272 TEXT (If more space is required.

use additional copies of NRC Form 366A) I 17) PLANT AND SYSTEM IDENTIFICATION Westinghouse

-Pressurized Water Reactor Liquid Waste System (LWS) {WD/-}* Chemical and Volume Control System (CVCS) {CB/-}* LER NUMBER (6) YEAR I SEQUENTIAL I REVISION NUMBER NUMBER 98 -004 -00 PAGE (3) 2 OF 5

• 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 in Mode 4 (Hot Shutdown) and Unit 2 was in Mode 5 (Cold Shutdown) . DESCRIPTION OF OCCURRENCE During a root cause investigation of a related event that occurred on February 24, 1998, violations of Salem TS 4.11.1.1.2, Radioactive Effluents, and TS 3.3.3.8, Radioactive Liquid Effluent Monitoring And Instrumentation, were identified.

These violations first occurred on January 3, 1996, when the Offsite Dose Calculation Manual (ODCM) was revised by Revision 10 to add a Safety Factor to the radioactive effluent calculation used to determine radioactive liquid effluent monitor setpoints and release rates. The Safety Factor was added to account for non-gamma emitting radionuclides that cannot be detected by installed radiation monitoring equipment.

Prior to this revision, the ODCM did not use a Safety Factor in these calculations.

However, a Safety Factor was used by the implementing procedure SC.CH-TI.ZZ-0140(Q), Radiological Liquid Effluent Discharges, and in the RETS software used to perform the calculations.

This did not constitute a violation of the TS requirement to perform these calculations in accordance with the ODCM because the calculation methodology in the procedure and in the RETS software used the ODCM methodology, but added its own Safety Factor for additional conservatism.

At.the time the revision to the ODCM was implemented, station personnel did not recognize that the Safety Factor used in the RETS effluent software, the radioactive effluent implementing procedures, and to determine the radioactive liquid effluent monitoring instrumentation setpoints, did not agree with the ODCM. Station personnel also did not recognize the impact of that condition on the licensing basis. Specifically the requirement of TS 4.11.1.1.2 to use the results of radioactivity analyses in accordance with the ODCM to assure that release concentrations are maintained within TS limits; and the requirement of TS 3.3.3.8 to determine radioactive effluent monitoring instrumentation channel alarm setpoints in accordance with the ODCM was not *recognized.

From the time that ODCM Revision 10 was implemented on January 3, 1996, until the Safety Factors in the ODCM, the procedure, and the software were brought into agreement on October 23, 1997, surveillances performed to satisfy TS 4.11.1.1.2 were not performed in accordance with the ODCM and therefore constituted violations of TS. Additionally, during that time period, radioactive effluent monitoring instrumentation channel alarm setpoints were not set accordance with the ODCM, constituting a violation of TS 3.3.3.8. During the implementation of ODCM Revision 10, the Safety Factor itself was incorrectly documented in the ODCM. The error in the ODCM revision communicated the Safety Factor as [.25] vice [l-.25 or .75] and resulted in multiplying release rate and setpoint by [.25] NRC FORM 366A (4-95)

'* NRC FORM 366A (4-95) U ** NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER) TEXT CONTINUATION FACILITY NAME (1 l DOCKET NUMBER (2) LER NUMBER (6) YEAR I SEQUENTIAL . I REVISION NUMBER NUMBBl SALEM UNIT 1 05000272 98 -004 00 TEXT (If more space is required, use additional copies of NRC Form 366A) ( 17) DESCRIPTION OF OCCURRENCE (Cont.) PAGE (3) 3 OF 5 instead of [.75]. Since the link between the the ODCM and the TS was not recognized, the effect of this error was not immediately felt. The error was first identified on September 9, 1996, by a controls engineer.

This engineer determined that the conservative Safety Factor would likely result in numerous Control Room alarms because radiation monitor setpoints would be set to 25% of their previous values. Based upon discussions with the author of ODCM Revision 10, the controls engineer determined that the intent of the revision was to use a Safety Factor with a value of [. 75] and not [. 25] . The contr.ols engineer then used the "intended" value [. 75] for Safety Factor and not the actual value of [.25] for setpoint determination.

Again, the controls engineer did not recognize the link between the ODCM and the TS. Because the setpoints were changed to a value derived using the "intended" and not the actual Safety Factor value of the revision to the ODCM, the setpoints remained in a state of compliance with TS 3.3.3.8 until this .discrepancy was corrected on March 14, 1998. When apprised of the. Safety Factor error, the author of Revision 10 incorrectly concluded that the design engineers were using the Safety Factor outside of its intended purpose, that it was derived from radioactive liquid waste data, and that it was not intended for use with other radioactive waste monitors.

This demonstrated a clear lack of understanding that TS 3.3.3 .. 8 encompasses all radioactive liquid effluent monitoring instrumentation and is not restricted to liquid waste effluent monitors.

From that point on, the author of the ODCM revision considered that this issue was restricted to the incorrectly documented Safety Factor in the ODCM and did not recognize that a condition

• adverse to quality existed. Although identified, the Safety Factor documentation error in the ODCM was not corrected at that time. On September 19, 1997, a Quality Assurance audit identified the Safety Factor discrepancy between the ODCM, the procedure, and the RETS software.

However, the audit failed to recognize the relationship between the TS and the ODCM, or to identify that the station was not in compliance with TS. As a result of this audit, the RETS software was modified on September 19, 1997, to obtain agreement with the ODCM. In error the Safety Factor was changed to [.75] and not [.25] as documented in the ODCM. The Safety Factor in procedure SC.CH-TI.ZZ-0140(Q) was revised on September 23, to a value of [.25] to conform to the ODCM Safety Factor. The error in the Safety Factor in the RETS software was identified and was again changed in October 23, from [.75] to [.25] to conform with the ODCM. At that time the procedure and the RETS software were both in compliance with the Safety Factor in the ODCM. From that point forward, surveillances performed to satisfy TS 4.11.1.1.2 using the RETS software and. procedure SC.CH-TI.ZZ-0140(Q) would comply with TS, but with an unneccesarily conservative Safety Factor. Radioactive liquid effluent monitor setpoints remained at values calculated using the [.75] Safety Factor. On January 3, 1998, during the preparation of two radioactive liquid release permits, Chemistry Department personnel altered the permits by changing the Safety Factor used by the RETS software from [.25] to [1]. The Safety Factor was changed to remove a quarterly dose projection "flag" that was generated by the RETS software.

The "flag" alerts Chemistry Department personnel when additional processing of the effluent ip necessary prior to release to ensure that the dose limit _is not exceeded.

The Safety Factor was changed as a work-around by the Chemistry Department personnel who recognized that the flag was caused by the overly conservative Safety Factor of [.25] used by the software.

Because the ODCM does not require the use. of a Safety Factor in the dose calculation required by TS 4.11.1.3, this calculation was correctly performed to ensure that dose limits of TS 3.11.1.3 and 10CFR20 were not exceeded.

NRC FORM 366A (4-95)

NRC FORM 366A (4-95) U.S. UCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER) TEXT CONTINUATION FACILITY NAME 111 DOCKET NUMBER 121 LER NUMBER 161 YEAR I SEQUENTIAL I REVISION NUMBER NUMBER SALEM UNIT 1 05000272 98 -004 -00 TEXT (If more space is required, use additional copies of NRC Form 366AI I 171 DESCRIPTION OF OCCURRENCE (Cont.) PAGE 131 4 OF 5 The RETS software used the same formula to calculate the release rate. Because the release rate calculation in the ODCM (since the implementation of Revision 10) required the use of a [.25] Safety Factor, TS 4.11.1.1.2 was violated when the Safety Factor was changed to [l] . A subsequent review of these releases demonstrated that the concentration limits of TS 3.11.1.1 were not exceeded.

On March 14, 1998, ODCM revision 11 was approved which incorporated the [.75] Safety Factor into the setpoint calculation.

This brought the Safety Factor used to calculate release rate and radioactive liquid effluent monitor setpoints in the procedure, the RETS software, and the ODCM into agreement.

Additionally, this action brought Radioactive Liquid Effulent Monitor setpoints into alignment with the ODCM and TS 3.3.3.8 was satisfied.

CAUSE OF OCCURRENCE . The apparent cause of this event is an organizational deficiency in the implementation of the Radioactive Effluents/ODCM program as evidenced by inadequate program monitoring and management as well as a lack of program evaluation.

Contributing to this occurrence was an overall lack of understanding by station personnel of the role of the ODCM in the station's licensing basis. PRIOR SIMILAR OCCURRENCES A review of LERs for Salem Units 1 and 2 issued in the last two years identified one LER that discussed a related occurrence.

LER 272/97-007-00 reported a violation to TS 3. 3. 3. 8, Radioactive Liquid Effluent Monitoring Instrumentation.

This viola,tion was caused by the failure of station personnel to independently verify the radioactive liquid waste release valve lineup as a compensatory measure required by TS when the radioactive liquid effluent monitoring instrumentation is out of service. SAFETY CONSEQUENCES There were no safety consequences as a result of this event. A review of the releases performed between the implementation of Revision 10 to the ODCM on January 3, 1996, and the time that the discrepancy between the ODCM, the RETS software, and the procedure were corrected on October 23, 1997; and a review of the releases on January 3, 1998, revealed that in no case were the concentration limits of TS 3.11.1.1 exceeded.

Additionally, although Effluent Radiation Monitor setpoints were not set in accordance with the ODCM as required by TS, at no time were the setpoints set to a value that would have permitted the concentration limits of TS 3.11.1.1 to be exceeded for batch or continuous release. CORRECTIVE ACTIONS 1. The releases performed between the implementation of Revision 10 to the ODCM on January 3, 1996, and the time that the discrepancy-between the ODCM, the RETS software, and the procedure was corrected on October 23, 1997; and the releases on January 3, 1998 were reviewed to verify that the concentration limits of TS 3.11.1.1 were not exceeded.

2. On March 14, 1998, the Safety Factor was corrected in the ODCM by implementation of Revision 11. Additionally, the implementing procedure and RETS software were revised to align with this change. NRC FORM 366A (4-95)

NRC FORM 366A (4-95) U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER) TEXT CONTINUATION YEAR I SEQUENTIAL I REVISION NUMBER NUMBBl SALEM UNIT 1 05000272 98 -004 -00 5 OF 5 TEXT (If more space is required, use additional copies of NRC Form 366A) 117) CORRECTIVE ACTIONS(Cont.)

3. Radioactive liquid effluent monitors were declared inoperable because of the incorrect Safety Factor applied to their setpoint.

Following implementation of ODCM revision 11, the setpoints were restored to compliance with the ODCM. 4. Appropriate personnel involved with the errors have been held accountable in accordance with PSE&G's procedures and policies.

5. Improvements to ODCM effluents program controls and review process will be implemented to ensure that adequate interface exists between design engineering, effluents software, radiation monitor set points, and the implementing procedures . . (00980224081, CRCA 12, to be completed by 6/15/98) 6. Training will be provided to appropriate personnel on the effluents program and its licensing basis. (00980224081, CRCA 04, to be completed by 6/15/98, CRCA 29, to be completed by 9/30/98.)

7. An independent review of the ODCM will be performed to ensure that it is consistent with available regulatory guidance.

(00980224081, CRCA 17,to be completed by 7/15/98) 8. Ownership for the ODCM has been formally defined and assigned.

NRC FORM 366A (4-95)