ML20062C333
| ML20062C333 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 10/19/1990 |
| From: | Fitzpatrick E GENERAL PUBLIC UTILITIES CORP. |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 9010310111 | |
| Download: ML20062C333 (3) | |
Text
-
_,*j t
l
+-
G" ; ti Nuclear
- en:r888 OPU Nuclear Corporation Forked River, New Jersey 087310388 609 971 4000 Writer's Direct Dial Number; i
4 October 19, 1990 Mr. Thomas T. Martin Regional Administrator U.S. Nuclear Regulatory Commission l
475 Allendale Road King of Prussia, PA 19406 Dear Mr. Martin
Subject:
Oyster Creek Nuclear Regulatory Commission-l Docket No. 50-219 i
Response to Notice of Violation NRC letter dated September 6, 1990 forwarded Inspection Report 90-13 and a_
Notice of Violation pertaining to effluent radiation monitoring at Oyster I
Creek. Attachment I to this letter provides GPU Nuclear's-response to the-violation.
As discussed with Mr. W.
Ruland of the NRC Region 1 office, the due date for this response was extended to October 19, 1990 since GPUN did not receive the Notice of Violation until September 19, 1990.
If further information is required, please call Mr. Michael Heller, Licensing Engineer, at (609)971-4680.
Very truly yours, E. E. Fitzpatrick-Vice President and Director Oyster Creek l
EEF/MGH/dmd Winov90-13 O'
wp s
O' cc: USNRC fZ O
Attn Document Control Desk Washington, DC 20555 l
O wg NRC Resident Inspectc*s c
M Oyster Creek Nuclear Generating Station 100 s
at
\\Q gg ggoj GPU Nuclear Corporation is a subsidiary of General Public Utilitie Corporation.
IIl%
4 e
s ATIACEMENT I Violationi Section 3.15.A of the Radiological Effluent Technical Specifications states
)
in part that "When less than the minimum number of radioactive liquid effluent monitoring instrumentation channels are OPERABLE, take the ACTION shown in Table 3.15.1.
Make every reasonable effort to restore the instrument to OPERABLE status within 30 days and, if unsuccessful, explain in the next Semiannual Radioactive Effluent Release Report why the inoperability was not corrected in a timely manner."
Contrary to the above requirements, the radwaste overboard discharge radiation monitor has been inoperable since the issuance of the Radiological Effluent Technical Specifications in 1986. No reasonable effort has been made to restore the monitor to operable status.
In fact, this monitor has been inoperable since October 1982.
Reenonset CPUN agrees that having a Technical Specification required effluent monitor out-of-service for a period of years should not have occurred.
- However, GPUN does not agree that the inoperability of the liquid radwaste ef fluent monttor constitutes a violation of the intent or the literal Technical Specification requirement.
Oyster Creek has operated with very limited batch liquid discharges.
These discharges have been performed using the sampling and analysis technique required by the Technical Specifications when the effluent monitor is inoperable. The basic requirement is to measure and control releases.
The alternate method employed assures releases are within limits.
Prior to implementation of the radiological effluent technical specifications (RETS) in October _1986, the Oyster Creek technical specifications (TS) identified sampling and analysis of batch discharges as an acceptable alternative to continuous monitoring.
There were no action requirements to repair the monitor within a specified time or to report'its inoperability at that time.
GPUN formally notified the NRC by letter dated August 13,-1986 that the liquid radwaste effluent monitor had been inoperable since 1981 and the proposed resolution was to delete the requirement for this monitor based on a cost / benefit analysis performed in August 1985. At several meetings held with the NRC project manager it was agreed that it would be acceptable to implement the RETS and propose deletion of the monitor via a technical specification change request (TSCR) with the understanding that the action statements for inoperable equipment in the proposed RETS would allow GPUN to operate Oyster Creek within the RETS.
" Response (cont'd)
The NRC safety evaluation report (SER) for the RETS amendment acknowledged GPUN's intention to propose deletion of the requirement for the liquid radwaste effluent monitor.
The SER also identified other effluent monitoring instrumentation needing upgrade prior to restart from the cycle 12R outage (September, 1988). NRC Inspection Report 90-13 quotes a paragraph in the SER concerning this equipment and concludes that GPUN failed to restore the liquid radwaste effluent discharge monitor prior to
{
restart from the cycle 12R outage.
That quote was taken out of context.
It is documented that GPUN's intentions were to delete the monitor, not restore its operability by the above date.
Further, NRC Generic Letter 07-09 dated June 4, 1987 provides the following guidance concerning limiting conditions for operation (LCo):
' Consistent with NRC's regulatory requirements for an LCo, the TS include two basic types of Action Requirements that are applicable when the LCO is not met.
The first specifies the remedial actions that permit continued operation of the facility not restricted by the time limits of Action Requirements.. In this case, conformance to the Action Requirements provides an acceptable level of safety for continued operation of the facility, and operation mav croceed indefinite 1v as lona as the remedial Action Recuirements are met". (emphasis addeo)
GPUN acknowledges that a TSCR to delete the liquid radwaste effluent monitor has not yet been submitted. While this should not have gone on so long, the NRC knew and accepted GPUN's approach. Currently, GPUN intends to submit a TSCR by the end of this year to request relocation of the RETS to exis';ing licensee controlled documents in accordance with Generic Letter 89-01.
Once this change is approved by the NRC, GPUN intends to delete the requirement for the monitor in accordance with 10CFP50.59.
(W:NOV90 13)
_ _ - - -