ML20087A901
| ML20087A901 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 09/24/1970 |
| From: | Bovier R JERSEY CENTRAL POWER & LIGHT CO. |
| To: | Low L US ATOMIC ENERGY COMMISSION (AEC) |
| Shared Package | |
| ML20086U000 | List:
|
| References | |
| FOIA-95-36 NUDOCS 9508070215 | |
| Download: ML20087A901 (6) | |
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This letter is in reply to you-letter of September 9, 17,'O that set forth a number of items wherein it appeared to your in::;cetors that certain activities at Oycter Creek Station were not conducted in full compliance with the license requirements.
In addition, you requested cccments regarding certain aspects of the functioning of our Safety Connittee and our organization for j
staLion operation.
These comments are also included. The let-tered paragraphs below respond to similarly lettered paragraphs
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in your letter:
t A. As a result of the start-up test pro 6 ram, a cituation had developed which indicated a possibility of steam leakage through one of the Cour main ste:.m line isola-tion valves. After a review by the POh0 and GORB of data obtained at a special check made on Decent,er 13, 1969 with the reactor at approxit:.ately 660 psig, DEL was notified by telephone on Decer.ber 16, 1969 and by letter on December 2h, 1969. Since there is r.o estab-i 1
lished criterion to correlate high pressure steam leakage to the Technical Specifications leakage crite-f rion of a cold 20 psi dir test,_ the December 24, 1969 report indicated there would be a plant shutdown pricr to February 1,1970 for the purpose cf cheer.ing the leakage under the Technical-Specificction test condi-tions. The res.ctor was shut down on January 31, 1970 to test main steam isolation valves; and during a shutdown on April 19, 1970, the valvas were again j
tested in a continuing program of monitoring the performance of these valves. The written reporte of March 20, 1970 and June 3,1970 vere supplemental
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to the December 2h, 1969 report.
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Mr. Icyrence D. Lov Page II September 24, 1970 i
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1 Although the results of this testing were immediately reported P
verbally, it would appear, in view of your letter, that we mis-I interpreted the reporting requirements of the license.
You vill be promptly advised of similar events in the future; and if a report is required, it will be filed.
B. Secondary containment integrity is defined in regard to access doors as having at least one door to each access opening closed.
In the compliance exit interview on January 8, 1970, we were advised that both railroad air lock doors were closed but not dogged. Both doors were dogged immediately and the incident was investigated.
Although the individual who caused this equipment to be left in this condition cannot be identified, it was determined that construction personnel had entered the air lock through the outer door and left that door as found.
Permission to open the inner access door had been granted to start-up personnel by a Jersey Central Shift Foreman, who failed to check the security of the doors.
Construction personnel have nov left the site.
To eliminate the requirement of opening the large doors for personnel access to this area, man-sized doors have been in-stalled which are controlled through a padlock arrangement.
C. The reactor achieved criticality for the first time on May 3, 1969.
The standby gas treatment system particulate filters were tested on June 17, 1969; January 19, 1970; and August 18, 1970. Thus, on two occasions, the tests were not completed vithin the required six-month interval, being lace by about I
i one month each time. To allow for unanticipated testing delays, we have rescheduled these tests for intervals shorter I
than the required six-month interval to avoid a recurrence of these events. The next test will be performed before the due date of February 18, 1971.
D. We do not believe that the reactor was operated on January 1, 1970 vithout the required number of operable high steam line flow trip systems.
With the reactor at approximately 1/4 load after a plant start-up, the totalized indicated steam flev l
began to decrease.
It was a period of approximately two hours before the flow returned to normal as compared to the feedvater flow.
The cause of the decrease was not known at that time.
There was no clear evidence at that time that the decrease in 4
indicated steam flow was the result of a loss in steam flov e
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Mr. savrence D. Low i
><.ge III re;te:.ber 24, 1970 i
l differential pressure measurement, which would also have affected high steam line flow sensed on the same sensing
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lines. During the evaluation of this incident, the e:: cess flow check valve was tapped by plant personnel.
Thus, it was first assumed that the excess flow check valve had been stuck. However, while steam flow indicatien was slowly in-creasing toward normal indication, the valve was checked and found to be open.
94bsequent events have established a probable cause of the Ja..unry 1,1970 incident which would not have affected the 1.!gh ateam flov trips. On January 9, 1970, the reactor nernamed on low level caused by a failure of the steam flow signals.
Both steam flow signals failed downscale indicating lov steam flow.
After it was determined that the pressure-sensing equipment was operating satisfactorily, a check of the electronic circuitry disclosed the fact that there vere two loose connections on the function generator output cir-cuit, which provide density correction to steam flow measuring circuitry. All connections to the three element control system vore checked and tightened.
Since this event, the loss of steam flow has not been repeated.
It is; therefore, concluded that the plant had not operated without adequate sensing of high flow in the main steam lines.
E. The failure of a fitting on a pressure sensing line, which connected to two electromatic relie*f valve pressure sensors, made the two valves inoperable for automatic pressure relief.
These relief valves were still operable for auto depressuriza-j tion and remotely operable from the control room.
The failure occurred while a man was tightening the fitting to stop a small i
drip and repair was initiated Dumediately. The repair and return of instrumentation to normal operable condition was completed in fifty minutes.
Thia time is very short in comparison to the time required to shut down and depressurize the reactor.
These valves are backed up by sixteen spring-operated safety va.1ves.
At the time of the failure, an evaluation by plant personnel determined that the repair time would be short and that it would be prudent to maintain steady operatin5 conditions since shutdown vould increase the possibility of pressure transients' To insure close observation and prompt action in case of a pressure tran-t sient, the two licensed control room operators were advised of the situation and instructed to watch reactor pressure closely
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and take action to open the valves mcnually if the need nrose.
In addition, the senior licensed shift foreman l
remained in. the 'contrql room during the repair.
Station cmergency procedures c411 for close surveillance of pres-sure during transient conditionc and require the operator i
to manhn11y operate equipment which might fail to operate from am.cmatic initiation.
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'The Technical Specification: do not have a limiting condi-tien fer opration coricertug these valves as pressure relief v,d.es, however, in view of the comments in your letter, the
.,. J for ::uch a specification la being investigated. We vill interd you of the findings of this investigation and propose rueh a specification, if required,- on completion of the investigation.
l T. Stens D. and E. vere not reported as Technical Specification j
viclations since they were not judged to be violations.
I However,_we realize there can be differences in-interpretation.
Etation management personnel have been instructed to continue Lo 2Yeely advisF our assigned compliance inspector of plant j
venditions and to file reports concerning items where inter-
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4 fretatien of our license requirements is difficult.
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- 0. The second control rod drive became inoperative on April lb, 3970. All partially' or fully vt,thdrawn control rod drives vere not exercised on April 15, 1970 as they should have been. When the oversight was discovered, drive exercises a
began on April 16,1970 and continued until plant shutdown for drive repair work.
Therefore, compliance was achieved 1
on April 16, 1970. This surveillance requirement has been reviewed with all plant licensed personnel.
i During the period covered by your letter of September 9, 1970, i
the following actions were taken by the GORB to improve the effec-tivenesu of audits and increase the participation of GORB in efforts to minimize the probability of a recurrence of plant operating problems:
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- 1. A formal Internal Audit Procedure (QAP-15) was initiated.
~i This procedure defines the responsibilities, systematic approach, and follow-up actions of personnel assigned to perform plant audits.
In addition, it assures proper and timely communications concerning the audit findings,
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!b*. Laurence D. Low Page V September 24, 1970 corrective actions required, and corrective action completion between the plant staff, PORC, and GORB members.
- 2. In order to improve participation of GORB members at PORC meetings, regularly scheduled FORC meetings have been initiated and the Vice Chairman of GORB has been made a member of PORC.
- 3. To ada depth in operating experience, particularly Oyster Creek's operations, the former Operations Supervisor at Oyster Creek has been assigned as a member and Vice Chairman of GORB.
In addition, the Manager of Safety and Licensing has been assigned as a member of GORB.
In addition, during the period covered by your letter of September 9,1970, the following actions have been taken to realign and strengthen the organizational structure that is responsible for the operation of our nuclear facilities:
- l. On April 28, 1970, Mr. Robert H. Sims, Vice President, assumed the responsibility for operation of the Company's Production Department.
- 2. Al-on April 28, 1970, responsfbilities within cur Production Department were divided; and Mr. Ivan R.
Finfrock was named Manager of Nuclear Generating Stations.
This arrangement allows the Manager of Nuclear Generating Stations to concentrate all of his energies toward the unique operational and ad-ministrative require nents of our nuclear stations.
- 3. Three personnel assigned to the Station participated in Senior Reactor Operator License examinations and received their licenses on August 3, 1970.
- h. A training program for seven additional Reactor Operators and one additional Senior Reactor Operator was instituted, and these men are scheduled for ex-I amination on October 21-24, 1970.
- 5. Two Associate Engineers assigned to the Station have completed the appropriate training, attained the o
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required experience, and demonstrcted their coursetence I
in order to allow their assignment as Ascintant' Tech i Engineers.
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- 6. Two Associate Engineers have been added to the plant stat '
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T. Two Staff En61ncers have been added to the plant staff w :,r,,..
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- 8. Two Assistant Technicians have been added to the S technical group to reinforce the radiation and ch s
control aspects of Station operation.
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- 9. One Instrument and Control Technician has been ad plant staff.
e Creek Station personnel, for providing for contingWe have yster Oyater Creek Station organization, and for developi encies within the future nuclear stations.
t ng personnel for your representatives, at any mutually con,enient timeWe vonld be pis you may have relative to this response to your letter l
, any questions
.I Very traly yours, j
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,j. F. Bovier President pk Dr. Peter A. Morris l
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