ML20217Q322
| ML20217Q322 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 03/31/1998 |
| From: | Roche M GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1940-98-20133, 50-219-97-10, NUDOCS 9804100397 | |
| Download: ML20217Q322 (5) | |
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l GPU Nuclear inc.
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U.S. Route #9 South NUCLEAR P**t 0"'c' B** 388 Forked River, NJ 08731-0388 Tel 609-971-4000 March 31,1998 1940-98-20133 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555
Dear Sir:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 IR 97-010: Reply to Notice of Violations In accordance with 10CFR 2.201, the enclosed provides GPU Nuclear's response to the violations identified in the subject inspection report.
As documented in our correspondence of March 12,1998 an extension was granted until March 31,1998.
Ifyou should have any questions, or require further information, please contact Brenda DeMerchant, Oyster Creek Regulatory Affairs Engineer, at 609-971-4642.
Very truly yours, he hfHfl Michael B. Roche Vice President and Director Oyster Creek MBR/BDE/gl
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Attachment cc:
Administrator, Region I NRC Project Manager NRC Sr. Resident Inspector
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9804100397 980331 PDR ADOCK 05000219L G
ATTACHMENT I Violation 1 Technical Specification 3.1.B.3 requires that except during the performance of Technical Specification required LPRM/APRM (Local Power Range Monitor / Average Power Range Monitor) surveillance testing reactor power shall be reduced below the 80% rod line or the corresponding RPS (Reactor Protection System) trip system shall be placed in the trip condition whenever all three of the following conditions exist:
1.
Reactor power is greater than 35% and 2.
More than one LPRM detector is bypassed or failed in the A Level or the B level assigned to a single APRM channel, and 3.
The diagonally opposite quadrant contains a single APRM channel with more than one bypassed or failed LPRM detector on the same axial level as the bypass or failed detectors specified in 2 above.
Dgurintiw "iolation:
Contrary to the above, on February 21,1995, the licensee placed the unit in a lineup in which the above three conditions existed simultaneously, to perform a test not required by Technical Specifications, and did not reduce reactor power below the 80% rod line or place the corresponding RPS trip system in the tripped condition. Specifically, with reactor power at 100%
and B level LPRMs 04-25 and 20-25 (associated with APRM channel 7) in the bypassed condition, the licensee removed APRM channel 5 (located in the diagonally opposite quadrant) to perform non-Technical Specification testing.
1 GPUN 'Resnonse GPUN does not concur with the violation and offers the following additional information:
When this situation was originally identified in February 1995, Operations Management evaluated this issue and determined that the routine adjustment of APRM Gain Adjustment Factors and the LPRM Current Calibrations were enveloped as part of the Technical Specification required surveillances. Section 4.1, Protective Instmmentation, indicates in Note 2, "at least daily during reactor POWER OPERATION, the reactor neutron flux peaking factor shall be estimated and flow-referenced APRM scram and rod block settings shall be adjusted, if necessary, as specified in Section 2.3 Specifications A.1 and A.2." The activities in question were being conducted to comply with the requirements in Note 2 of Table 4.1,1, i
Even though the Technical Specifications do not list the adjustment of the APRM Gains or the Calibration of the LPRMs in Table 4.1.1, Minimum Check, Calibration and Test Frequency for Protective Instrumentation, the performance of these activities are required to ensure that the APRMs are accurately reading reactor power. Additionally, the definition of" operable -
operability" in the plant's Technical Specifications specifically requires that equipment must be
" capable of performing its specified functions (s)" and "the assumption that all necessary attendant instrumentation, controls,.. " which implicitly requires the performance of these activities. If these calibrations were not performed and simply the electronic checks of the APRM drawers were performed, then the accuracy of the APRMs would be questionable and the APRMs could not be considered operable.
Violation 2 Technical Specification 6.8.1 requires that written procedures shall be established, implemented and maintained covering the activities recommended in Appendix 'A' of Regulatory Guide 1.33.
Regulatory Guide 1.33, Appendix ' A' recommends procedures for the control of radioactivity, including procedures involving radiation monitoring systems (RMS).
Contrary to the above, as of October 24,1997, the licensee had failed to establish and implement adequate RMS calibration procedures as evidenced by: (1) no documentation or poor documentation of the electronic calibration data, (2) inadequate testing to determine optimum operating high voltage, (3) incorrect performance of the secondary calibration, and (4) no determinations of conversion factors and linearity for the intended monitoring ranges.
This is a Severity Level IV Violation (Supplement IV).
GPUN Response GPUN concurs with the violation as stated.
Even though the station's established calibration procedures complied with Regulatory Guides 1.21 and 4.15, our current RMS (radiation monitoring system) calibration procedures lack consistency with industry standards and will be improved.
Subsequent to Inspection 97-02 and the subject inspection we recognized that our calibration practices should be upgraded and that the resultant product would substantially improve the validation of the equipment's performance.
Corrective Actions That flave Been Taken and Results Achieved Substantial data was accumulated and plotted to substantiate our current calibration practices.
The calibration procedures are being revised and implemented to comply with the suggested methods.
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c-AdditionalCorrective Actions:
S In order to address the deficiencies as noted in the subject Inspection Report, the following corrective actions are being implemented:
The monitors using scintillation detectors will have their calibration procedures revised to incorporate a plat =u check of the high voltage. Additionally, the scintillation detectors will have their calibration procedures revised to incorporate a three point check.
The revision of the calibration procedures will produce the data necessary to determine conversion factors andlinearity.-
Date When Full Compliance Will Be Achieved The procedures are scheduled to be revised prior to the next scheduled calibration or by December 31,1998, whichever is sooner.
Violation 3 Technical Specification 6.8.1 requires that written procedures shall be established, implemented and maintained covering the activities recommended in Appendix 'A' of Regulatory Guide 1.33.
Regulatory Guide 1.33, Appendix 'A' recommends procedures for the control of radioactivity, including procedures directed to performance verification ofventilation systems.
Contrary to the above as of October 24,1997, the licensee failed to establish and implement
. procedures to verify that the design basis relative to air balance affecting the Auxiliary Offgas (AOG) building, New Radioactive Waste (NRW) building, and turbine building area ventilation systema, was maintained within the specifications as described by the Updated Final Safety Analysis Report.
This is a Severity Level IV Violation (Supplement IV).
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GPUN Response GPUN concurs with the violation and agrees with the assessment in the inspection report that the cause of the violation was due to a lack of oversight on the Turbine Bldg., New Radwaste, Old i
Radwaste, and Offgas Building ventilation systems.
Corrective Actions Taken and Results Achieved The operators' tour sheet of the AOG (AOG and Boiler House Turnover Checklist) has been revised to read and record the differential pressure of the AOG from an existing instrument.
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Corrective Steps to be Taken to Avoid Further Violations The operators' tour sheet for the New Radwaste Building (Radwaste Tour and Turnover Checklist) will be revised to read and record the differential pressure of the NRW Building from an existing instrument.
Presently, differential pressure data of the Turbine Building. Condenser Bay is not being collected due to ALARA concerns because the instrument is located in a contaminated area. This pressure gauge is not presently functional and will be replaced during the second quarter of this year.
Therefore, pressure readings may be resumed but at a less frequent cycle due to the same ALARA concerns. There is a project to install a new differential pressure gauge in the control room.
When that instrument is installed the Turbine Building Tour Sheet will be revised to read and record the differential pressure of the Turbine Building from this new instrument.
Date When Full Compliance Will Be Achieved Full compliance will be achieved with the installation of the new Turbine Building pressure gauge in the Control Room. This is scheduled to be completed prior to the end of the founh quarter of 1998.
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