ML20216H999
| ML20216H999 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 04/14/1998 |
| From: | Hehl C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Roche M GENERAL PUBLIC UTILITIES CORP. |
| Shared Package | |
| ML20216J005 | List: |
| References | |
| 50-219-97-11, EA-98-049, EA-98-49, NUDOCS 9804210279 | |
| Download: ML20216H999 (3) | |
See also: IR 05000219/1997011
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April 14,1998
EA 98-049
Mr. Michael B. Roche
Vice President and Director
GPU Nuclear incorporated
Oyster Creek Nuclear Generating Station
Post Office Box 388
Forked River, New Jersey 08731
SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50 219/97-11)
Dear Mr. Roche:
This letter refers to the NRC inspection conducted December 29,1997 through February 8,
1998, at your Oyster Creek nuclear facility. During the inspection, apparent violations of
NRC requirements were identified and were discussed with you and members of your staff
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at an exit meeting on February 13,1998. The inspection report was sent to you on March
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10,1998. On March 23,1998, a predecisional enforcement conference (conference) was
conducted with you and members of your staff, to discuss the violations, their causes, and
your corrective actions.
Based on the information developed during the inspection, and the information provided
during the conference, one violation of NRC requirements is being cited and is described in
the enclosed Notice of Violation (Notice). For the first apparent violation example identified
in the inspection report, concerning the adequacy of the safety review for installation of
the containment spray heat exchanger relief valve gagging device, we concluded that your
safety determination adequately addressed why the gag was not a change to the facility as
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described in the Final Safety Analysis Report. Accordingly, no violation of 10 CFR 50.59
existed in this case. For the second example, concerning the use of a freeze seal as the
primary containment boundary, the NRC has determined that your failure to conduct a
safety evaluation for the work activity was a violation of 10 CFR 50.59.
With respect to the above violation, on January 15,1998, your staff installed a freeze seal
on a 3/4 inch pipe that was part of the primary containment boundary, but located in the
secondary containment (reactor building), in order to remove and replace a containment
spray heat exchanger relief valve. However, your staff failed to perform the necessary
safety evaluation as required by the controlling job order and 10 CFR 50.59. As a result,
the freeze seal was installed without determining that the change to the containment
boundary did not involve an unreviewed safety question (USO). The NRC has determined
that an adequate safety evaluation for this freeze seal should have concluded that a USQ
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existed due to the possibility of creating an accident or malfunction of a different type than '
any previously evaluated in the UFSAR (the failure of the freeze seal following an accident
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resulting in bypassing containment via the 3/4 inch line directly to the reactor building).
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9804210279 980414
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ADOCK 05000219
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Mr. Michael B. Roche
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Your safety evaluation, completed after-the fact on January 16,1998, was inadequate
because it did not provide sufficient bases to conclude that the consequences of an
accident previously evaluated in the UFSAR were not increased or that the possibility of a
different type of accident or malfunction than previously analyzed was not created.
The NRC is concerned that you failed to recognize the significance of performing
maintenance on your primary containment boundary while operating at full power. At the
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conference, you indicated that senior station management was aware of the relief valve
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repair activities. Notwithstanding this awareness, it was apparent that management was
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not involved and knowledgeable to the extent of ensuring that the design and licensing
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bases were met prior to conducting the freeze seal activity. This violation is of concern
because the NRC relies upon licensees correctly assessing changes to the plant licensing
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bases to ensure that USQs do not exist. Although this change involved a USQ, the
potential safety consequences of the freeze seal activity were low due to the use of
maintenance isolation valves, the short duration of the activity, and the small size of the
relief valve line. Therefore, this violation has been categorized at Severity Level IV.
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The NRC is also concerned that your staff failed to demonstrate an adequate understanding
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of your technical specifications. At the March 23,1998, cui.*erence, your staff stated that
operators complied with the primary containment integrity requ%ments of Technical Specification 3.5.A.3.a., because this technical specification allowed 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to isolate the
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penetration before entering the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> action statement of Technical Specification 3.5.A.7. However, since the leaking relief valve (V-21-?3) is not listed in Technical
Specification Table 3.5-2, Conta/nment / solation Valves, this specification was not
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applicable, and the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> action statement should have been entered as soon as it was
recognized that the primary containment boundary was degraded.
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You are required to respond to this letter and should follow the instructions specified in the
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enclosed Notice when preparing your response. The NRC will use your response, in part,
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to determine whether further enforcement action is necessary to ensure compliance with
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regulatory requirements.
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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter,
its enclosure, and your response will be placed in the NRC Public Document Room (PDR).
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Sincerely,
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Richard Crienjak/for
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Charles W. Hehl, Director
Division of Reactor Projects
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Docket No. 50-219
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License No. DPR-16
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Enclosure:
2. Oyster Creek Containment Spray Relief Valve Replacement
Handouts
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Mr. Michael B. Roche
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cc w/ encl:
G. Busch, Manager, Nuclear Safety and Licensing, Oyster Creek
M. Laggart, Manager, Corporate Licensing
State of New Jersey
Distribution w/ encl:
Region 1 Docket Room (with concurrences)
Nuclear Safety Information Center (NSIC)
NRC Resident inspector
PUBLIC
H. Miller, RA/W. Axelson, DRA (irs)
M. Evans, DRP
N. Perry, DRP
J. Yerokun, DRS
A. Linde, DRP
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J. Lieberman, OE
B. McCabe, OEDO
P. Milano, NRR/PD l 3
C. Thomas, NRR/PD 1-3
R. Correia, NRR
F. Talbot, NRR
DOCDESK
Inspection Program Branch, NRR (IPAS)
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To receive a copy of this document, indicate in the box: "C" = Copy without
attachment / enclosure
"E" = Copy with attachment / enclosure
"N" = No copy
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DATE
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OFFICIAL RECORD COPY
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