ML20195J845
| ML20195J845 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek, Crane |
| Issue date: | 11/12/1998 |
| From: | Fornicola J GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20195J850 | List: |
| References | |
| RTR-REGGD-01.143, RTR-REGGD-1.143 1940-98-20636, 1940-98-20641, NUDOCS 9811250086 | |
| Download: ML20195J845 (2) | |
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GPU Nuclear, Inc.
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U.S. Route PJ South NUCLEAR P 0"'c. 8 x 3as Forked River, NJ 087310388 Tel 609-971-4000 1940-98-20636 1920 98-20641 November 12,1998 U.S. Nuclear Regulatory Commission Attn: Document Control Desk I
I Washington, DC 20555 Gentlemen,
Subject:
Operational Quality Assurance Plan Change Without Proper Notification Oyster Creek Nuclear Generating Station, (OCNGS)
Docket No. 50-219 Three Mile Island Nuclear Generating Station Docket No. 50-289 The purpose of this letter is to submit a change previously made to GPU Nuclear's Operational Quality Assurance (OQA) Plan without the appropriate notification to the NRC. When Revision 6 of the OQA Plan was submitted to the NRC it did not include a segment in Appendix C related to Regulatory Guide (RG) 1.143. When Revision 7 was submitted, it included the change but it was not indicated as a change. Specifically, the change is clarification 4 regarding the use of hose in lieu of pipe for temporary connections. (Copy attached)
' Appendix C to the OQA Plan is a summary of the commitments GPU Nuclear has made to various Regulatory Guides. It also specifically lists exceptions to those Regulatory I'
Guides. GPU Nuclear has committed in the OQA Plan to follow the guidance of RG f
1.143 " Design Guidance for Radioactive Waste Management Systems, Structures and Components Installed in Light-Water-Cooled Nuclear Power Plants". Several exceptions have been taken to the guidance and three such exceptions were submitted to the NRC.
g[j A fourth exception was inserted into the OQA Plan without properly notifying the NRC.
I The fourth exception concerns the use of hoses in lieu of piping under certain limited situations. The first condition for the use of hoses is that the connection be temporary. In l
addition, prior to use, the hoses are to be hydrotested to the appropriate pressure for the system or component to which they are connected. After installation they are to receive regular hydrotesting or in-service inspections. Finally, a safety evaluation is required to justify the use of such hose connections.
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.The constraints indicated above ensure that any liquid or solid radwaste will be appropriately collected, treated, stored and processed during the time that hoses are used in lieu of piping.
Exception 4 to RG 1.143 was prepared for inclusion in Revision 6 of the OQA Plan that was effective in December 1992. When Revision 6 was submitted to the NRC, however, the change was not included. Revision 7 of the OQA Plan, which was effective in April 1994, includes the change but it is not noted as a change. The reason the change was not included in Revision 6 is not clear. When Revision 7 was prepared, however, the change
- had been incorporated into the word processing file and was not identified as a change in our submittal per 10 CFR 50.54(a).
GPU Nuclear regrets the error and believes that there are now sufficient controls over the word processing file to preclude a similar occurrence.
If additional information is required, please contact Dennis Kelly of my staff at (609) 971-4246.
-Sincer
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J. C. ;Pornicola pirector, Nuclear Safety Assessment cc:
RegionI Administrator Oyster Creek Project Manager Oyster Creek Senior Resident Inspector l
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