ML20136D588
| ML20136D588 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 11/07/1985 |
| From: | Fiedler P GENERAL PUBLIC UTILITIES CORP. |
| To: | Kister H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8511210328 | |
| Download: ML20136D588 (4) | |
Text
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, p GPU Nuclear Corporation Nuclear e:=;g;388 Forked River,New Jersey 08731-o388 609 971-4000 Wnter's Direct Dial Number:
November 7, 1985 Mr. Harry B. Kister, Chief Division of Project and Resident Programs U.S. Nuclear Regulatory Comission Region I 631 Park Avenuc King of Prussia, PA 19406
Dear Mr. Kis'ter:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 Inspection Report No. 85-23 This letter forwards GPUN's response to Notices of Violation A and B contained in Inspection Report 85-23, dated October 7,1985.
If there are any questions regarding this submittal, please contact Kathy Barnes at (609)971-4680.
Very truly yours, t
A LJ
'i dl r Vice President and Director Oyster Creek PBF/KB/ dam Attachments cc: Dr. Thomas E. Murley, Administrator Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Mr. Jack N. Donohew, Jr.
U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue, Phillips Bldg.
Bethesda, MD 20014 Mail Stop No. 314 12 ggfK 500 9
NRC Resident Inspector Oyster Creek Nuclear Generating Station Forked River, NJ 08731 t
GPU Nuclear Corporation is a subsidiary of the General Pubhc Utilities Corporation g
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Attachment Violation A Technical Specfication 6.8.1 requires, in part, that written procedures be established, implemented, and maintained. Station Procedure 700.2.014, "Backseatin V-16-1 (Electrically),g and Unbackseating Valves V-14-36, V-14-37, and provides instructions for unbackseating a containment. isolation valve without making the automatic isolation function inoperable.
Contrary to the above, during a plant shutdown conducted on February 2, 1985, operators failed to follow procedure 700.2.014 while unbackseating a reactor water cleanup system containment isolation valve. This deviation from the procedure made the automatic isolation function of a containment isolation valve inoperable when it was required to be operable.
Response to Violation A Violation "A" was issued as a result of operators failing to follow Procedure 700.2.014 while unbackseating a reactor water cleanup system containment isolation valve. When this operation was performed, operators had ~the option to unbackseat the valve utilizing Procedure 700.2.014, or by following the instructions provided in Standing Order No. 33. The standing order requires only that the valve be closed and then reopened. The operators chose to utilize the instructions in tne standing order, but deviated from the instructions upon recognition that the valve (V-16-1), when given a close signal, would " seal in" and thus result in full closure and subsequent loss of the Cleanup System. Loss of the Cleanup System at this time was considered undesirable in that it would reduce the ability to control reactor water level during the shutdown process. Therefore, it was decided to trip the valve breaker, thus interrupting the close signal. An electrician was stationed at the valve breaker in communication with the Control Room. This provided the operator with the capability to maintain control over the valve and also allow him to immediately override and shut the valve if required.
It
'was not intended to defeat an isolation function, nor was it intended to leave the breaker in the OFF (open) position.
The operators were fully aware that valve V-16-1 was a primary containment isolation valve.
It was intended only to operate the valve locally (at' the breaker) to prevent actuation of the seal in circuit.
It was not realized at this time, however, that once the closing circuit was energized, a trip of the system would occur.
Following the trip of the system, caused by opening the associated breaker, the system subsequently received an isolation signal and immediate corrective action was taken.
The valve breaker was reclosed and the valve closed to provide proper isolation control.
The valve was left in the closed position until completion of the shutdown process
-(reactor coolant temperature less than 2120F) at which time the
-Cleanup System was returned to service.
..., ' Corrective action taken to avoid recurrence was to issue a change to the standing order to provide additional instructions to the operator regarding unbackseating of specific valves. This revision (No. 3) became effective Apri_1 30,1985. The Licensee Event Report (LER 85-002) associated with this event has been assigned to all licensed operators as required reading and in addition the Manager of Plant Operations has reviewed this event with every operating shif t during the Plant Status
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meetings.
Violation B Technical Specification 6.8.1 requires, in part, tnat written procedures i
be estanlished, implemented and maintained. Station Procedure 312,
" Reactor Containment Integrity and Atmosphere Control," provides detailed instructions for the inerting of the drywell and torus.
These instructions include" (1) a prerequisite to calibrate the drywell and torus oxygen analyzers, (2) instructions to use 150" of nitrogen from the nitrogen storage tank, (3) a note to inert until both drywell and torus are less than 3% oxygen, (4) instructions to ignore the oxygen analyzer readings until they are calibrated with the containment less than 4% oxygen. Also, Station Procedure 201.2, " Plant Heatup to Hot Standoy," and the Technical Specifications require containment be inerted to less than 4% oxygen within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after placing the reactor in the RUN mode.
Contrary to.the above, during a startup conducted on August 4,1985, Station Procedures 312 and 201.2 were not fully adhered to in that: (1) a prerequisite which required an oxygen analyzer calibration was not -
1 completed prior to initiating inerting, (2) less than 150" of nitrogen was utilized during inerting, (3) the drywell and torus were not inerted
-to less than 3% oxygen, (4) specific instructions to ignore oxygen analyzer readings were not followed, and (5) operation was conducted 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after placing the mode switch in RUN with the drywell oxygen concentration at 4%.
Response to Violation B Violation "B" was issued as a result of failing to adequately inert the drywell and torus during plant startup. During the startup process, inerting had been completed up to the point that recalibration of the e
oxygen analyzers was procedurally required.
The calibration commenced, L
but was aborted due to an inadequate supply of calibration gas. At that time, the oxygen analyzers indicated between 3.5% and 4%. A decision j ~
was subsequently made to go into tne run mode; however, no procedure
(-
- change was issued to authorize this variation.
The decision to proceed was based primarily on the results of the previous analyzer calibration
- completed approximately eight hours earlier, and also due to the delay
)
expected in the receipt of additional calibration gas.
There was no
]
intent to violate any procedural requirements.
The decision was based on an evaluation of the previous calibration and the need to achieve a more stable operating condition. The 150" requirement was considered an I
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- approximate number and until this incident had not been understood as a requirement.
No additional inerting activities were initiated until the calibration gas was received, at which time concentration could be verified.
As indicated in the incident critique, written subsequent to this event, the primary cause was poor judgement in decision making, lack of strict procedural compliance and insufficient followup. GPU Nuclear believes that this is an isolated incident and is not indicative of a trend to r
violate procedural requirements.
Immediate corrective action was taken when the calibration gas was received. The oxygen analyzers were calibrated and the drywell/ torus reinerted to less than 3% oxygen.
Corrective actions taken/to be taken to avoid recurrence include:
1.
As noted, this incident was a result of failure to follow approved procedures. The cause and effects have been discussed internally between management personnel and first line supervisors with major
- emphasis being placed on the need for tnorough review, consultation and consnunication during this type of decision making. The need to review Technical Specifications, review procedures and consider temporary or permanent revisions to procedures was also stressed.
2.
Alternate methods for determining oxygen concentration to assure it
'is' below 3% prior to going to the run mode will be examined and t
appropriate procedure changes executed, if necessary.
3.
'A staff meeting was held by the Division Vice President to discuss this incident with plant managers.
4.
Senior Operations personnel involved were counselled directly by the Division Vice President regarding the importance for strict procedural and Technical Specification adherence or implementing approved changes through established processes when required.
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5.
It was established that concurrence from upper plant management is needed prior to implementing major changes in plant conditions (such as going to the the "run" mode).
6.
A copy of the incident critique has been provided as " Required
. Reading" for all shifts.
7.
A review of the plant management organization will be performed to assess its effectiveness in this area.
No future deviations from procedural requirements are anticipated regardless of any forthcoming procedure changes.
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