ML20070K123
| ML20070K123 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 07/19/1994 |
| From: | J. J. Barton GENERAL PUBLIC UTILITIES CORP. |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20070K098 | List: |
| References | |
| C321-94-2117, NUDOCS 9407260111 | |
| Download: ML20070K123 (6) | |
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n GPU Nuclear Corporation Nuclear
- = ei = 388 Forked Rwer, New Jersey 08731-0388 609 971-4000 Wnter's Direct Dial Number:
July 19,1994 C321-94-2117 Thomas T. Martin Administrator, Region i US Nuclear Regulatory Commission 475 Allendale Road King of Prussia PA 19406-1415
Dear Sir:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 Documentation for Exercise of Discretion Pursuant to 10 CFR 2, Appendix C(VII).C " Exercise of Discretion for an Operating Facility", this letter is being written to document a request for enforcement discretion from the Oyster Creek Nuclear Generating Station Technical Specification action statement requirements to have the the reactor shutdown within the speciGed time limits.
During a plant walkdown for the purposes of evaluating electrical panel seismic acceptability, a concern with the seismic adequacy of two electrical panels was identined. After evaluation and operability determination, the systems controlled through these panels were declared inoperable and a plant shutdown initiated. Due to the short period of time necessary to restore these panels to full seismic acceptability, coupled with the low probability of a Loss of Coolant Accident occurring, GPU Nuclear decided ts request enforcement discretion which would allow the plant to return to full power. The basis for the request was communicated to the Administrator, Region 1, via a teleconference including GPU Nuclear, the NRC Operations Center, and the NRC Duty Of6cer, Region 1.. Attachment I to this letter provides t'ne information described in 10 CFR 2.
On July 18,1994, at 8:25 pm, the Administrator granted enforcement discretion to delay the initiation of a reactor shutdown for a period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> in order to install the modified supports. The modi 6 cation installation was completed by 4:00 am, and the systems were declared operable at i1:00 am on July 19,1994, when the modi 6 cation paperwork was completed and approved.
9407260111 940720 POR ADOCK 05000219 P
PDR GPU Nuclear Corporabon is a subsdary of Genera! Pubhc Ubblies Corporabon
C321-94-2117 Page 2 A Licensee Event Report will be submitted within 30 days to complete the documention of this condition, if any additional information or assistance is required, please contact Mr. John Rogers of my staff at 609.971.4893.
m John J. Barton O
Vice President and Director Oyster Creek JJB/JJR Attachment cc:
Senior Resident Inspector Oyster Creek NRC Project Manager Associate Director for Projects, NRR Associate Director for Inspection and Technical Assessment, NRR Division Director, Division of Reactor Projects, NRR Director, Office of Enforcement Document Control Desk Technical Assistant, Division of Reactor Projects - 1,11, NRR
ATTACHMENT I BASIS FOR REQUEST FOR EXERCISE OF DISCRETION 10 CFR 2, Appendix C, Section VII directs the licensee to provide:
1.
The_ Technical. Specification.or_otherJicense_ conditions that_willbe_ violated.
Technical Specification 3.4 Emergency Cooling; Section B, Automatic Depressurization System requirement B.3:
"If Specification 3.4.B.1 and 3.4.B.2 are not met; reactor pressure shall be reduced to 110 psig or less, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."
Technical Specification 3.4 Emergency Cooling; Section C, Containment Spray System and Emergency Service Water System requirement C.7:
"If Specifications 3.4.C.3...are not met, the reactor shall be placed in a cold shutdown condition...."
Technical Specification 3.0. A establishes a time limit of 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> when individual specifications provide no time limit.
2.
The circumstances. surrounding thesituation.jncluding_theaieed for_ prompt action.
During the course of Seismic Qualification Utility Group (SQUG) walkdowns on July 18,1994, it was discovered that the control panels which house the control logic relays and associated wiring for portions of the Automatic Depressurization System and Containment Spray System were not restrained sufficiently to assure operability during a seismic event.
Specifically, it was determined that the control panels would tip in such a fashion that the associated relays and control wiring operability cotdd not be assured.
Based upon this discovery, redundant trains of Containment Spray and Emergency Service Water systems were declared inverable, and the Automatic Depressurization System was declared inoperable. Accordingly, a plant shutdown was commenced in accordance with the appropriate Technical Specification Limiting Conditions for Operation (3.4.B.3,3.4.C.7, & 3.0. A).
C321-94-2117 Attachment I Page 2 3.
The safety _ basis.for_the. request that_ enforcement _ discretion _be exercised, including.an evaluatiort of the_ safety. significance _and_ potential. consequences _of the proposed course of action.
The safety significance of this request is considered minimal for the following reasons:
The modifications which would bring the plant within its design basis seismic requirements thus restoring " full qualification" will proceed on a continuous basis until complete. The estimated time for completing these modifications is 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
The probability of a seismic event of sufficient magnitude to overturn these panels in combination with a Loss of Coolant Accident is extremely low, especially when considering the small amount of time that this condition will exist.
Compliance with the Technical Specification requirements require that the plant be shutdown which would impose an unnecessary transient on the plant.
4.
Any. proposed compensatory. measure (s)
The following compensatory measures have been initiated:
Reactor operators will be briefed on this issue. The expected operator response to a seismic event will be discussed.
An inspection of these panels and appropriate testing of the associated systems will be performed following any seismic event that may occur until these panels can be properly anchored and restored to full qualification.
5.
The justification _for_the. duration _of_the. noncompliance The period of time estimated to complete installation of the necessary modification is comparable with the time period required to conduct a plant shutdown. Additionally, the low probability of these events does not warrant the increased risk of a plant transient attendant with a plant shutdown.
2 C321-94-2117 -
Attachment I Page 3 6.
The. basis.for_the licensee's. conclusion.thalthe_non: compliance _willJmLbe_of potential detrimenLto the public_ health _and. safety _and.thala.SignificanLhazard_is not involved.
The low probability of these events does not warrant the increased risk of a plant transient attendant with a plant shutdown especially when considering the small length of time that these panels will remain outside of compliance with the seismic qualification requirements.
None of these systems is required to support a safe plant shutdown. As such, the safety significance of this condition is limited to the extremely low probability of a seismic event in combination with a loss of coolant accident.
Even in the unlikely event that these events were to occur, the existing Symptom Based Emergency Operating Procedures provide alternate direction for assuring core cooling and containment integrity.
7.
The basis for_the_ licensee's_ conclusion thalthe. noncompliance _will.notinvolve ad ve rse. conse q uences. to. the. e nvironment There is no environmental impact associated with this request for discretionary enforcement. The low probability of these events coupled with the short.
estimated time period for restoring these panels to full qualification results in no adverse effects to the environment.
8.
A statement that thefequest has been approved.by_the_ facility ntganization.that -
normally2eviews. safety _ issues (ElanLOnsite Review._ Committee,.or its equivalent).
The Plant Review Group has reviewed and concurred with this Request for Exercise of Discretion.
C321-94-2117 Page 4 9.
Any.other..information the}lRCataff deems necessarybefore making.a_ decision to exercise discretion A teleconference call on July 18, 1994. T. Martin, W. Lazarus, and J. Sebrosky of the USNRC discussed this concern,vith GPU Nuclear Representatives J. Barton, A. Rone, P. Scallon, W. Behrle, K. Mulligan, and J. Rogers. Based on this call, enforcement discretion was granted at 8:25 pm which allowed the Oyster Creek Nuclear Generating Station to delay the initiation of a reactor shutdown for a period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. GPU Nuclear committed that a written Request for Enforcement Discretion would be submitted to the NRC on July 19, 1994. This letter fulfills that commitment.