ML20042E500

Forwards Rev 1 to Topical Rept 028, Oyster Creek Response to NRC Reg Guide 1.97.

ML20042E500
Person / Time
Site:	Oyster Creek
Issue date:	04/13/1990
From:	Fitzpatrick E GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20042E501	List: ML20042E500 ML20042E503
References
RTR-NUREG-0737, RTR-NUREG-737, RTR-REGGD-01.097, RTR-REGGD-1.097 GL-82-23, NUDOCS 9004230311
Download: ML20042E500 (3)

Text

G OPU Nuclear Corporation N Iear One Upper Pond Road Parsippany, New Jersey 07054 201 316 7000 TELEX 136-482 Writer's Direct Dial Number:

April 13,1990 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Gentlemen:

Subjects Oyster Creek Nuclear Generating Station Docket No. 50-219 Topical Report 028, Rev. 1, "OC Response to US NRC Regulatory Guide 1.97" In response to NRC Generic Letter No. 82-23 dated December 17, 1982, GPUN provided detailed descriptions on conformance to Regulatory Guide (Reg.

Guide) 1.97 Revision 2 by letters dated June 13, 1984 and May 9, 1986.

The GPUN May 9, 1986 letter transmitted Topical Report 028 which listed Reg. Guide 1.97 variables at Oyster Creek, proposed modifications for certain variables and provided justification for exceptions from Reg.

Guide 1.97 recommendations.

Subcequently, the NRC staff and their consultant, Idaho National Engineering Laboratory (INCL), reviewed the Topical Report No. 028. On September 5, 1987 the staff transmitted the Technical Evaluation Report j (EGG-NTA-7277) stating that there were issues for which INEL could not

j. conclude that adequate justification for exceptions from Reg. Guide 1.97 recommendations were provided. GPUN responded on March 30, 1988 by providing further justification for the deviations. It is our understanding that the Staff will prepare a Safety Evaluation Report (SER) j in the near future.

We have recently reviewed our previous submittals as well as several audit reports generated by the NRC staff regarding Reg. Guide 1.97 compliance at j' several nuclear power stations. After the review we concluded that' l Topical Report 028 should be revised to provide additional clarifying information for certain variables, to adopt the report format recommended in NUREG 0737, Supplement 1 and to include updated information thereby providing more accurate inputs to the forthcoming NRC SER concerning OCNGS Reg. Guide 1.97 compliance. To this end we recently revised Topical Report 028 to address the above issues. Revision 1 of the report supersedes the previously submitted Topical Report 028 and is being transmitted by this letter.

95 PDR w Q0 'h P. i GPU Nuclear Corporation is a subsidiary of General Pubhc Utilities Corporation e

h

67 US NRC REGULATORY GUIDE 1.97-PAGE 2 It must be noted, however, that we have identified several deficiencies.as described in Table III of the attached. Topical' Report 028, Rev. 1. The deficiencies'are currently undergoing evaluation and we will provide our plan for resolution by the end of the third quarter of the calendar year

1990.

A summary of the changes made to Topical Report 028 is provided below.

1. ' Instrument Identification Numbers'(Tag Numbers)

The previously submitted version of the report listed Rog. Guide.

1.97 variables without the corresponding instrument id6ntification numbers. The revised topical report _ identifies the tag number (s) for each variable in the format recommended inL NUREG 0737, Supplement 1.

2. Reg. Guide 1.97 Modifications Topical Report 028, Rev. O was submitted on May 9, 1986. Since that time several plant modifications have been performed which affect Reg. Guide 1.97 compliance. Table III of the revised' topical report reflects the current status of category 1 and 2 Reg. Guide 1.97 instrumentation.

3. Oyster Creek Design Criteria and Exceptions The introduction to Table II in Rev. 1 of the report delineates those areas where GPUN is taking exceptions from Reg. Guide 1.97 recommendations. Comparison of the Reg. Guide 1.97 criteria to the criteria in use when the original OCNGS instrument channels were installed and justification for the existing installation-are provided.

4. Reformatting Table III of the report has been-reformatted'to adopt a format recommended by NUREG 0737, Supplement 1, The new format shows how each variable conforms to the Reg. Guide 1.97 recommended design and quality assurance criteria. Additional actions needed to satisfy the Reg. Guide 1.97 criteria are also listed.

5. Additional deficiencies Additional deficiencies' identified are listed in Table III of the revised report.

6. Responses to Previous NRC Questions on July- 11, 1988 the NRC staff requested a conference call with GPUN to discuss Reg. Guide 1.97 issues. During the conference call the Staff stated they had reviewed the Topical Report 028 Rev. O and had' questions concerning:

1) the status of the GPUN evaluation concerning'possible future installation of the Wide Range Neutron Monitoring System, I

l.

I US NRC REIULATORY CUIDE 1.97

-PAGE 3--

2) qualification states of the containment spray 50 flow valve position indicator used for torus cooling and

3) justification for categorizing the Standby Liquid control System Storage Tank level indicator as Category 3.

Our responses to the above concerns were provided during the conference call and are documented in the following sections of the Topical Report No. 028, Rev. 1;

. Response to Question 1) ....... See page 57 (Table III)

Response to Question 2) ....... See page 67 (Table III)'

Response to Question 3) ........ See page 41 (Table II)

7. Corrections Topical Report'028, Rev. 1 includes certain corrections which are mostly editorial in nature (e.g. typographical errors, footnotes no longer applicable due to completion of plant modifications).

=We believe that the attached Topical Report 028, Rev. I will help the  ;

Staff in preparing an SER for OCNGS by providing updated, more detailed  ;

information concerning OCNGS conformance to Reg. Guide 1.97. l If you have any questions regarding this letter, please contact Mr. Michael W. Laggart, Manager, BWR Licensing at (201) 316-7968.

Very uly yours, E. E. Fit trick Vice President and Director Oyster Creek

{

EEF/YN/cb r (C320360) j.

cci Mr. William T. Russell, Administrator

• Region I U.S. Nuclear Regulatory Commission 475 Allendale Road = j King of Prussia, PA. 19406- l NRC Resident Inspector

{

Oyster Creek Nuclear Generating Station Forked River, N.J. 08731 .

i Mr. Alex Dromerick _

U.S. Nuclear Regulatory Commission .l Mail Station P1-137 .i Washington, D.C. 20555

]

4 1

I