ML20100C941

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Responds to NRC Re Violations Noted in Insp Rept 50-219/84-34.Corrective Actions:Operating Procedure 233, Drywell Access & Control, Issued on 841229
ML20100C941
Person / Time
Site: Oyster Creek
Issue date: 03/21/1985
From: Fiedler P
GENERAL PUBLIC UTILITIES CORP.
To: Kister H
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8504010005
Download: ML20100C941 (2)


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GPU Nuclear Corporation NggIgf Post Office Box 388 j

Route 9 South j

Forked River,New Jersey 08731-0388 609 971-4000 Writer's Direct Dial Number:

March 21, 1985 Mr. Harry B. Kister, Chief Division of Project and Resident Programs U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406

Subject:

Oyster Creek Nuclear Generating Station Docket No. 50-219 Inspection 84-34 Attachiaent I to this letter provides our response to the Notice of Violation contained in Appendix A of your letter dated February 20, 1985.

In the event that arly comments or questions arise, please contact Mr. Drew Holland of my staff at (609)971-4643.

Very truly yours, Ad Y P ter edler Vice President and Director Oyster Creek P8F/DGH/ dam (0928A)

Attachment cc: Dr. Thomas E. Murley, Administrator 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 8504010005 850321 ADOCK 050 9

gDR GPU Nuclear Corporation is a subsidiary of the General Pubhc Utikties Corporation g

4 g-g 4

~ ATTACHMENT.I VIOLATION:'

s As.a result of the' inspection conducted on Nov.18 - Dec. 31,1984, and in accordance with the revised NRC Enforcement Policy -(10 CFR 2. Appendix C) published in the Federal Register on March 8,1984 (49 FR' 8583), the. following -

zviolation was-identified.

Paragraph 6.8.1 of the Oyster Creek Technical Specifications requires that

written procedures shall be established, implemented and maintained.

Paragraph 3.12 of Oyster Creek Radiological Control Procedure 902.5 states

. that prior to making a containment entry, sufficient control rods shall be inserted so' that'the GSS can verify the reactor is subcritical and power level is decreasing.

Contrary to the above, on November 23,-1984, a containment entry was made without first inserting control rods to make the reactor subcritical and

verify decreasing power level.

This is a Severity Level IV. Violation.

RESPONSE

GPUN concurs that a containment entry was made as described without first inserting control rods to make the reactor subcritical and verify decreasing i power level.

Immediate corrective actions inclu'ded prohibiting all drywell entries at partial power until a new Operations procedure (Procedure 233) was developed and issued.- The procedure was $ritten using input from senior. staff members from various disciplines and from reconsnendations included in two independent reports. All input was reviewed and the results incorporated into the drywell entry procedure. Specifically, the new procedure includes the following key elements:

1..

Specific responsibilities (personnel) are defined.

2.

Written verification of safety requirements.

3. - - Upper level Ops / Rad Con management approval.

4.

Lead person responsible for the entry identified.

5.-

Requirement for the GSS to assure all prerequisites are met.

The incident was reviewed by Radiological Controls and Operations Departments and detailed results of their investigations were written up by Radiological Controls.

In addition, the incident was reviewed by both departments for any

" lessons learned". Concurrently, a consultant performed an independent assessment of the incident, and subsequently made recommendations to the Vice President and Director, Oyster Creek.

No further corrective actions are anticipated at this time.

It was determined that the procedure violation was not willful. Full compliance was achieved on

December 29, 1984 with the issuance of Procedure 233, "Drywell Access and Control".

It should be noted that experience with the new procedure has

-indicated that it does in fact provide the degree of control necessary and has prevented any recurrence of a similar incident.