ML20215C297
| ML20215C297 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 12/03/1986 |
| From: | Fiedler P GENERAL PUBLIC UTILITIES CORP. |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8612150093 | |
| Download: ML20215C297 (4) | |
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GPU Nuclear Corporation NggIgf Post Office Box 388 Route 9 South Forked River, New Jersey 08731-0388 609 971-4000 Writer's Direct Dial Number:
December 3, 1986 Dr. Thomas E. Murley, Administrator Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406
Dear Dr. Murley:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 Response to Notice of Violation IE Inspection 86-24 Pursuant to the provisions 10CFR2.201, General Public Utilities Nuclear (GPUN) hereby submits the enclosed response to the Notice of Violation (NOV) contained in Inspection Report 50-219/86-24 dated November 4,1986.
In addition to the required response to the NOV, GPUN was requested to provide additional information pertaining to the delay in reporting and addressing a safety concern associated with the connection of two non-seismic pipe lines to the Emergency Service Water piping. As discussed in the inspection report, a Preliminary Safety Concern (PSC) was initiated May 21, 1984. The PSC procedure is normally used to identify conditions or situations which may effect plant safety. Generally, these concerns require additional review and analysis by one or more functional groups to ascertain the scope and relevance of the concern.
In this instance, GPUN concurs with the inspector's observation that eighteen (18) months was an excessive period of time to resolve this concern. At the time the FSC was initiated, it was felt that due to the historical measurement of pump ficw, adequate margin existed to supply system requirements assuming a rupture of the non-seismic lines. Following additional investigation it was found that in some instances adequate margin did not exist, however, it should be noted the analysis assumes worst case conditions which preclude the use of the redundant pumps (i.e., failure of one diesel generator). Additionally, the analysis also assumes a LOCA in conjunction with a seismic event which in light of events over the past several years has been recognized as a low probability event. This is discussed in draft NUREG 1030 " Seismic Qualifications of Equipment in Operating Nuclear Power Plants".
8612150093 861203 PDR ADOCK 05000219 G
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GPU Nuclear Corporation is a subsidiary of the General Pubhc Utihties Corporation MO \\
J Dr. Thomas E. Muricy, Administrator USNRC Page 2 In January 1986, GPUN had recognized the PSC procedure needed revision in order to accomplish its objective. This procedure is currently being revised to assure greater attention to the prompt resolution of identified concerns. The objectives of this revision are to (1) provide a formal mechanism for addressing " safety concerns"; (2) provide definitive criteria for safety concerns; (3) assign responsibility for disposition to the cognizant Technical Department; (4) establish required time contraints; and (5) assure existing mechanisms (other than PSCs) for reportability determinations are effectively utilized. Also being considered is the establishment of an overview committee to initially determine priority and reportability of identified concerns.
These revisions will enhance the timely resolution of these concerns in the future.
If you should have any questions please contact George Busch at (609)971-4909.
Very truly yours, Ov 3
P edler Vice President ana Director Oyster Creek PBF/GB/ dam (0258A)
Enclosure cc:
Mr. Jack N. Donohew, Jr.
U.S. Nuclear Regulatory Comission 7920 Norfolk Avenue, Phillips Bldg.
Bethesda, MD 20014 Mail Stop No. 314 NRC Resident Inspector Oyster Creek Nuclear Generating Station Forked River, NJ 08731 l
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. ENCLOSURE RESPONSE TO VIOLATION Violation 10 CFR 50.59, Changes, Tests and Experiments, permits licensees to make changes in the facility and procedures described in the Safety Analysis Report provided the change neither involves a change in the Technical Specifications or is an unreviewed safety question. This part further requires that for changes which are made, written safety evaluations be maintained which provide the determination that the change does not involve an unreviewed safety question.
Contrary to the above, between June 29 and July 18, 1986, changes were made to Procedure 307, Isolation Condenser System, Revision 27, and Procedure 2000-ABN-3200.01, Reactor Scram, Revision 2, which pennit, on a high water level condition N the reactor, the manual overriding of the automatic initiation of the isolation condensers. The isolation condenters are an engineered safety feature described in the Final Safety Analysis Report and are the key components in the Isolation Condenser system required by the Technical Specifications to be operable whenever the reactor coolant temperature is greater than 212*F. For this change, no written safety evaluation was prepared to determine that the change 1
was not an unreviewed safety question.
Response
i GPUN accepts the violation.
l Discussion The Isolation Condenser System provides the capability to remove decay i
heat from the reactor after scram or shutdown. The system is initiated j
automatically in the event of reactor high pressure. Prior tc the l
procedure changes referred to in the Notice of Violation, the procedure contained a caution statement to alert the operator of possible damage to isolation condenser piping when initiated with reactor high water level.
Such damage could occur due to the effects of water hammer in the piping.
c Over the past several years, industry as well as the NRC, has been concerned with water hammer in reactor systems. Operator training and l.
the procedure changes which were made are deemed necessary in order to assure the system is protected from possible failure and unavailability in the event of increasing reactor vessel water level.
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l' Although GPUN recognizes that a written safety evaluation of the procedure changes should have been made, these changes were not made without regard to safety concerns.
In accordance with applicable procedures, the procedure changes were thoroughly reviewed by engineering and operations personnel. This review concluded that increasing reactor water level above the isolation condenser steam lines would render the i
cooling function inoperable while introducing the possibility of water hammer in the line. Such water hammer could result in piping damage i
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, thereby incapacitating the system.
Isoiating the system upon increasing level precludes such damage and maintains system availability once water level returns to normal. Operator action to preclude automatic initiation of the isolation condenser under high. water level conditions does not defeat the safety function of the system since the cooling function is incapacitated when water level rises above the isolation condenser steam line penetrations in the vessel.
Prior to this inspection, GPUN recognized a weakness in the safety review process and corrective actions were initiated. The procedure which governs this process is 1000-ADM-1291.01. This procedure had been revised and issned prior to IE Inspection 86-24. The revised procedure became effective September 1,1986 and provides guidance to all GPUN divisions. Pursuant to this procedure, all GPUN divisions are to implement procedural controls establishing criteria to determine the level of review required. Plant procedure 130 was revised September 9, 1986 to require that safety reviews be conducted on those documents specified in procedure 1000-ADM-1291.01 which includes plant operating procedures. The controls implemented on September 9,1986 assure that safety evaluations of procedural changes are performed as required by 10CFR50.59.
Corrective Steps Taken A written safety evaluation was prepared for the procedural changes identified in the Notice of Violation. Additionally, the changes made to the safety review process discussed above clearly defines that written safety evaluations are required for such changes in the future.
No further corrective action is deemed necessary.
Date When Full Compliance Is Achieved Full compliance was achieved on September 9,1986.
i l
(0258A)