ML20058A808
| ML20058A808 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 07/30/1990 |
| From: | Fitzpatrick E GENERAL PUBLIC UTILITIES CORP. |
| To: | Martin T NRC |
| Shared Package | |
| ML20058A806 | List: |
| References | |
| NUDOCS 9010290206 | |
| Download: ML20058A808 (5) | |
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OPU Nuolest Carperst6en er Post Office Box 388 Route 9 South Forked River, New Jersey 087310388 l
609 971 4000 Wnter's Direct Dial Number; i
July 30, 1990 l
Mr. Thomas T. Martin Regional Administrator U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia. PA 19406 Dear Mr. Martins i
Subjects Oyster Creek Nuclear Generating Station Docket No. 50-219 Response to Notice of Violation F
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NRC letter dated June 25, 1990 contains a Notice of Violation pertaining to the condenser low vacuum scram setpoint which drifted past the Technical specification I
limit. This issue is addressed in NRC Inspection Report No. 50-219/89-81 dated February 14, 1990.. Attachment 1 to this letter provides CPUN's response to the violation and Attachment 2 provides the status of the commitments CPUN made at a management meeting with the NRC on April 30, 1990.
i GPUN was granted an additional 8 days to respond to this Notice of Violation, moving the due date to August 3, 1990. This extension was granted by W. Ruland, NRC Region 1, in a telephone conference with C. Busch, oyster Creek Licensing Manager, on July 27, 1990.
If further information is required, please call Mr. Michael Heller, Licensing l
Engineer, at (609) 971-4680.
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er truly yours,
/
G Ly ~
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'.1 itzpatrick
,y,Q Vice
' resident and Director l
ggu-Oyster Creek doN EEF/MH jc MU cc U.S. Nuclear Regulatory Commission Attna Document control Desk g<I Washington, D.C.
20555 o
NRC Resident Inspector 1
90..O Oyster. Creek Nuclear Generating Station GPU Nuclear Corporation is a subsidiary of General Pubbc Utilities Corporation
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Attachment f Violation:
Technical Specification 3.1, Protective Instrumentation, states, in part, that operating requirements for plant protective instrumentation are given in Table 3.1.1, Protective Instrumentation Requirements.
Table 3.1.1, requires the scram function trip setting for low condenser vacuum be set greater than or equal to 23 inches of mercury ("Hg), with a minimum of two (2) operable trip systems and a minimum of two (2) instrument channels per operable trip system.
Contrary to the above, on December 8, 1989, the scram function trip setting for low condenser vacuum was less than 23" Hg for both trip systems, resulting in less than two operable trip systems.
This violation has been evaluated as a Severity Level IV violation (Supplement 1).
Pesnonce:
GPUN concurs with the violation in that four out of six condenser low vacuum scram setpoints were found at values less conservative than the Technical Specification limit. The surveillance test results demonstrated that the low vacuum scram function was operable, and would have responded as designed for one of three sections of the a
In the other two sections, the low vacuum scram function was operable but at a slightly lower vacuum setpoint.
The cause of this occurrence is attributed to censing element drif t, and the lack of margin for drift in the acceptable "as left" setpoint in the calibration procedure.
The acceptable "as 'lef t" setpoint in the calibration procedure was 23 +.5 - 0 inches Hg vacuum. The Technical Specification limit is greater than or equal to 23 inches Hg vacuum.
GPUN does not agree with the NRC statement that this violation demonstrates the need to enhance the corrective action process.
Prior to this event, GPUN had initiated a program to review instrument setpoints and drif t characteristics to determine if setpoint changes would be appropriate.
GPUN met with the NRC on January 30, 1989 to discuss GPUN's approach for evaluation of the 39 Technical Specification instrument loop setpoints.
At that meeting, CPUN identified the absence of a margin between the low vacuum scram setpoint and the Technical Specification limit. GPUN identified that this condition was not a safety concern, and that calibration history up to January 30, 1989 showed that drift past the Technical Specification limit was not likely; setpoint drift had always been in a conservative direction.
Subsequently, I
the NRC staff considered CPUN's evaluation approach to be satisfactory according to NRC letter dated February 10, 1989.
Corrective actions taken to prevent recurrence of the violation are as follows:
1.
The acceptable "as left" setpoint in the calibration procedure was initially changed to 24 +.35 - 0 inches Hg vacuum to allow for expected instrument drift. After further statistical analysis, the as left setpoint was changed to 23.65 +.35 - O.
2.
By letter dated Hay 29, 1990, GPUN provided to the NRC the results of a statistical analysis of the 39 Technical Specification instrument loop setpoints. The letter providea our current plans to make setpoint changes and to improve instrument performance, where appropriate.
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s Attachment I Page 2 3.
GPUN completed an evaluation of the Technical Specification requirement for j
the low vacuum scram and has concluded that, although the scram provides no cafety function, the requirement should be retained in the Technical Specifications for condenser and turbine protection purposes. However, the scram setpoint can be reduced from 23 to 20 inches Hg vacuum to better accommodate routine condenser backwashing in the summer months when the margin between the operational vacuum and the scram setpoint is minimal.
Technical specification change Request No.188 was submitted on July 10, 1990 to propose this change.
GPUN's assessment of whether the Technical Specification requirement in Table 3.1.1 for the low vacuum scram adequately reflects the as-built design of the vacuum trip system is expected to be completed by October 30, 1990.
Full compilance was achieved on December 8, 1989 when the low vacuum scram setpoints were adjusted to be within tha acceptable range.
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Attachment II The folicwing provides the status of the various commitmente CPUN made at the management meeting with the NRC on April 30, 1990:
1.
Commitment:
Submit letter providing the status of the instrument setpoint review program.
Status:
Complete.
Letter dated May 29, 1990 provides the results of a statistical analysis of the 39 Technical Specification instrument loop setpoints. The letter provides our current plans to make setpoint changes and to improve instrunent performance, where appropriate.
2.
Commitments Evaluate Technical Specification requirements for revision or elimination of the low vacuum scram function.
Status:
GPUN has concluded that, although the scram provides no safety function, the requirement should be retained in the Technical Specifications for condenser and turbine protection purposes.
However, the scram setpoint can be reduced from 23 to 20 inches Hg vacuum to better accommodate routine condenser backwashing in the summer months when the margin between the operational vacuum and the scram setpoint to minimal. Technical Specification Change Request No. 188 was submitted on July 10, 1990 to propose this change.
GPUN's assessment of whether the Technical Specification requirement for the low vacuum scram adequately reflects the as-built design of the vacuum trip system is scheduled for completion by October 30, 1990.
3.
Commitment Conduct operator self-verification training.
Status:
This training began in May, 1990 and is scheduled to be completed by the end of July, 1990.
4.
Commitment:
Review guidance for use of information/ caution tags.
Status:
Procedure 108
- Equipment Control" is being revised to require the use of information tags for any component that is out of service, in order to alert operators to such conditions.
This is part of a major revision to Procedure 108 which is scheduled for completion by the end of December, 1990.
5.
Commitment Submit Licensee Event Report in accordance with 10CFR50.73 to report as-found scram settings.
Status:
Complete.
LER 89-23 submitted on May 18, 1990.
6.
Commitment Update scram function description in FSAR.
Status Revised description has been prepared and will be incorporated in Revision 5 of the FSAR which is scheduled to be submitted to the NRC in December, 1990.
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't Att* chment II
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Commitment:
Revise the Operations Plant Manual (OPM) to explain the operation of the condenser low vacuum sensing and trip mechaniom as appropriate.
Status:
The OPM revision is scheduled for completion in September, 1990.
8.
Commitment:
Evaluate the merit of providing interlocks for the main condenser valves, to prevent the backwashing of a condenser half with the corresponding half in any mode other than normal line up for operation.
Status:
CPUN has decided, instead of providing interlocks, the operating procedure will be revised to require the use of information tage when a condensor half is out of service.
This revision is scheduled for completion in October, 1990.
9.
Connitment :
Review Procedure 106
- Conduct of Operations" and look for any conflicts in the guidance given to operators on instrument verification.
Status:
Procedure 106 is being revised to make this guidance more consistent throughout the procedure.
This revision is scheduled for completion in October, 1990.
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