ML20064L448

Responds to NRC Re Violations Noted in IE Insp Rept 50-219/82-22.Corrective Actions:All Group Shift Supervisors Informed of Violation & How Tech Spec Should Be Applied in Future.Tech Spec Change Will Be Submitted

ML20064L448
Person / Time
Site:	Oyster Creek
Issue date:	01/07/1983
From:	Fiedler P GENERAL PUBLIC UTILITIES CORP.
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20064L443	List: ML20064L448
References
NUDOCS 8302150273
Download: ML20064L448 (3)

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GPU Nuclear hh gg P.O. Box 388 torked River, New Jersey 08731 609-693-6000-Writer's Direct Dial Number.

January 7, 1983

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Mr. Richard W. Starostecki, Director Division of Project and Resident

' " ' ICICEAID D3101E S Programs

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U.S. Nuclear Regulatory Commission

,3srtif1 RIP iC Region I 631 Park Avenue King of Prussia, PA 19406

Subject:

Oyster Creek Nuclear Generating Station Docket No. 50-219 Notice of Violation Dated December 7, 1982 In accordance with 10 CFR 2.201, the attachment to this letter provides our response tu the Notice of Violation contained in your letter of Dececher 7, 1982.

If you should have any questions, please contact me or Mr. Michael Laggart of my staf f at (609) 971-4643.

Very truly yours, W

Peter B. Fiedler Vice President and Director Oyster Creek PBF:PFC:jal Attachment cc:

Mr. Ronald C. Haynes, Ad.ninistrator Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 NRC Resident Inspector Oyster Creek Nuclear Generating Station Forked River, NJ 08731 8302150273 830207 PDR ADOCK 05000219 PDR O

GPU Nuclear is a part of the General Public Utilities System

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.g Attechasnt The Violation states:

Technical Specifications 3.1.A, 3.8, and Table 3.1.1.H requires that an operable trip system be available to cause isolation of an isolation condenser during power operation when reactor water temperature is above 2120F. The isolation system must be capable of automatically closing two redundant valves in the influent steam line and two redundant valves in the condensate return line of an isolation condenser whenever a high flow condition in either the steam or condensate return line is detected. If these specifications cannot be met, the isolation condenser must be manually isolated.

Contrary to the above, while the plant was operating $ith the reactor water temperature above 212 F, the following conditions were identified:

0 1.

On September 27, 1982, the isolation trip system for the

'B' Isolation condenser was not capable of automatically closing isolation valve V-14-32 in the influent steam line in that this valve was electrically defeated in the open position for about 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (to add packing) and the Isolation Condenser was not isolated.

2.

On September 29, 1982, the isolation trip system for the

'A' Isolation Condenser was not capable of automatically closing isolation valve V-14-31 in the influent steam line in that this valve was electrically defeated in the open position for about 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (to add packing) and the Isolation Condenser was not isolated.

This is a Severity Level IV Violation (Supplement I)

Response

We concur with the violation as stated.

Technical Specification Section 3.1.A, Table 3.1.1, Item H requires two (2) operable Instrument Trip Systeas to isolate the Isolation Condenser in the event of a high flow signal in either the inlet steam or condensate return lines.

This Technical Specification is not, however, specific regarding intent. One understanding, based upon the description of applicability of Section 3.1, was i

that this specification applies strictly to the protective instrumentation only, allowing one redundant isolation valve.to be inoperable. In this configuration, 'the trip systems would still be capable of isolating the l

Isolation Condenser with the remaining three valves. Therefore, in the j

instances described in the Notice of Violation and as discussed in the body of Inspection Report No. 82-22, both Isolation Condensers were operable to perform their intended function with adequate assurance that their isolation capability remained intact, although partial isolation redundancy was lost for a short duration of time. Conversely, the interpretation provided as the basis for the Notice of Violation requires that all four isolation valves for an Isolation l

Condenser must be capable of the isolation function at all times when the l

Isolation Condenser is in service. Consequently, for those periods when an l

isolation valve is rendered inoperable for a planned maintenance activity such as valve packing replacement, the af fected Isolation Condenser is to be isolated, resulting in the loss of a redundant heat sink.

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Re sponse:

(Continued)

Operations management, in its determination of system configuration for Isolation Condenser isolation valve maintenance, believed the Technical Specification allowed the flexibility of removing an isolation valve from service to add packing with reasonable assurance of isolation capability. The basis for this determination was that plant operation was more conservative as regards the ability to maintain both Isolation Condensers opsrable to perform their designed function.

We are currently evaluating this situation from a nuclear safety standpoint with regard to the appropriate action that should be_taken to provide for maximum plant safety. Regardless of the results, a Technical Specification Change Request will be submitted to clarify the present specification.

In order to prevent a recurrence of this violation, all Group Shif t Supervisors were informe/. of the violation and how the Technical Specification involved is to be applie.d in the future,,i.e., if an Isolation Condenser isolation valve is found to be, or rendered, inoperable, the af fected Isolation Condenser will be declared inoperable and isolated. Additionally, to reconfirm this understanding and to further assure all Group Shif t Supervisors are svare, the Manager - Plant Operations will issue a memorandum to all Shif t Supervisors discussing this violation and proper action to be taken.

Since the violation resulted from an Operations management decision, the corrective action stated is sufficient to prevent recurrence. Full compliance is being achieved.

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