ML20216H170

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Notice of Violation from Insp on 980226-0318.Violations Noted:Since Initial Plant Operation,Operators Implemented Procedure 307,isolation Condenser Sys,Permitting Fill & Make Up to Isolation Condensers During Normal Plant Operations
ML20216H170
Person / Time
Site: Oyster Creek
Issue date: 04/15/1998
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20216H154 List:
References
50-219-98-04, 50-219-98-4, NUDOCS 9804210076
Download: ML20216H170 (2)


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NOTICE OF VIOLATION GPU Nuclear Corporation Docket No. 50-219 Oyster Creek Nuclear Generating Station License No. DPR-16 During an NRC inspection conducted February 26-March 18,1998, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below.

1.

10 CFR 50.59, Changes, tests and experiments, specifies that the licensee may make changes to its facility and procedures as described in the safety analysis report and conduct tests or experiments not described in the safety analysis report without prior Commission approval, provided the change does not involve a change in the technical specifications or an unreviewed safety question (USQ); and requires the licensee to maintain records of changes in the facility, including written safety evaluations providing the bases for the determination that the change does not involve a USQ. Section 6.3.1.1.2 of the Oyster Creek UFSAR (Update 8; 8/93) states that "during normal plant operations, when the system is in Standby, makeup to the Isolation Condensers is from the Demineralized Water Transfer System," a normally non-radioactive system.

Contrary to the above, since initial plant operation (1969), operators implemented Procedure 307, Isolation Condenser System, which permitted fill and make up to the isolation condensers during norrnal plant operations, when the system was in Standby, by a means other than the Demineralized Water Transfer System.

Specifically, operators used the Condensate Transfer System, a normally radioactively contaminated system, to fill and make up to the isolation condensers when the system was in Standby, and a safety evaluation was not developed or written to provide the bases for the determination that the change did not involve a USQ.

This is a Severity Level IV violation (Supplement 1).

2.

Section 6.8.4.a.3 of Technical Specifications (TS) requires that a radioactiva effluent controls program shall be provided and include " Monitoring, sampling, and analysis of radioactive liquid and gaseous effluent in accordance with 10 CFR 20.1302 and with the methodology and parameters in the ODCM". Section 20.1302 of 10 CFR requires that "The licensee shall make or cause to be made, as approoriate, surveys of radiation levels in unrestricted and controlled areas and radioactive materials in effluents released to unrestricted and controlled areas to demonstrate compliance with the dose limits for individual members of the public in Section 20.1301." Section 20.1301 of 10 CFR specifies dose limits for individual members of the public, 9904210076 980415 PDR ADOCK 05000219 G

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2 Contrary to the above requirements, at least since December 1996, the licensee's radioactive effluent control program did not provide for the monitoring, sampling, and analysis of tritium that was generated and released from the isolation condenser system to unrestricted and controlled areas in order to demonstrate compliance with the dose limits for individual members of the public.

This is a Severity Level IV violation (Supplement IV).

Pursuant to the provisions of 10 CFR 2.201, GPU Nuclear Corporation is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region I, and a copy to the NRC Resident inspector within 30 days of the receipt date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation:

(1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken.

Where good cause is shown, consideration will be given to extending the response time, if you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction, if personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response deletes such information. If you request withholding I

of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

l Dated at King of Prussia, Pennsylvania this 15th day of April,1998 i

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