ML20236P466
| ML20236P466 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 07/09/1998 |
| From: | Roche M GENERAL PUBLIC UTILITIES CORP. |
| To: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| 1940-98-20334, 50-219-98-80, NUDOCS 9807160353 | |
| Download: ML20236P466 (4) | |
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GPU Nuclear,Inc.
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U.S. Route #9 South l
NUCLEAR P "'0"ic* B " 388 Forked River, NJ 08731-0388 Tel 609-9714000 l
i July 9,1998
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1940-98-20334 Mr. J. Lieberman, Director Office of Enforcement U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, Md. 20852-2738
Dear Sir:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 1R 98-80 Reply to Notice of Violation And Civil Penalty In accordance with 10 CFR 2.201, the enclosed provides GPU Nuclear's response to the violation issued subsequent to the May 29,1998 predecisional enforcement conference.
If you have any questions, or require additional information, please contact Dennis Kelly of my staff at 609-971-4246.
Very truly yours,
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s Michael B. Roche Vice President and Director Oyster Creek MBR/DPK Attachment cc:
Administrator, Region 1 NRC Project Manager NRC Sr. Resident Inspector l
NRC Document Control Desk
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4 Violation:
-A.
10 CFR Part 50, Appendix B, Criterion III (Design Control), requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design bases, as dermed in 10CFR50.2 and as specified in' the license
. application, for those structures, systems, and components to which this appendix applies, are correctly translated into specifications, drawings, procedures, and i
instructions. In addition, it requires in part, that the design control measures shall provide for verifying or checking the-adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational
- methods, or by the performance of a suitable testing program.
Technical Specification 3.4.B.1, Automatic Depressurization System, requires that the five electromatic relief valves of the automatic depressurization system shall be operable when the reactor water temperature is greater than 212 degrees and pressurized above 110 psig.
Contrary to the.above, prior to March 4,1998, the licensee failed to establish adequate design control measures to verify or check the adequacy of design voltage required for the Automatic Depressurization System (ADS) Electromatic Relief Valve (EMRV) solenoids to function under design basis accident conditions. Specifically, the licensee had not established a minimum required operating voltage, nor a minimum available voltage at the solenoid terminals during a design basis accident scenario, and therefore, could not certify that the EMRVs (and the related ADS) would operate in a design basis accident scenario.
As a result, only.two of the five EMRVs would have been functional to depressurize the reactor on a small break loss of coolant accident (SBLOCA) condition, concurrent wiih a Loss of Offsite Power and a single failure of emergency diesel generator #2 (specifically, Battery B Charger) contrary to TS 3.4.B.l.
B.
' 10 CFR 50.49(f) requires that each item of electrical equipment important to safety shall be qualified. 10 CFR 50.49(k) allows certain electrical equipment to be qualified in accordance with " Guidelines for Evaluating Environmental L
. Qualification of Class 1E Electrical Equipment in Operating Reactors,"
- November 1979 (DOR Guidelines).
. DOR Guidelines, Section 5.2, Qualification by Type testing, item 5, requires that operational modes tested should be representative of the actual application requirements (e.g. motor and electrical cable loading during the test should be representative of actual operating conditions). In addition, item 6, requires that
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the equipment qualification program should include an as-built inspection in the
, field to verify that equipment was installed as it was tested.
Contrary to the above, from November 1984 to March 1998, the application requirement for the five ADS EMRV solenoids in the EQ documentation (EQ-OC-301 dated August 1,1989) was not representative of the field installation and actual operating condition. No analysis was performed to validate the established qualification voltage (a minimum of 105 volts dc).
l These violations are classified in the aggregate as a Severity Level 111 Problem (Supplement I).
GPUN Response GPUN concurs with the violation as noted.
Reason for Violation Design control was less than adequate. No voltage drop calculations were in place to address the EMRV condition until March 1998. GPU Nuclear had not treated electrical considerations as rigorously as other Equipment Qualification (EQ) program parameters.
GPU Nuclear's Engineering Process did not assure that electrical characteristics analysis information from the EQ process was carried over to the design side. In addition, there was no clear ownership (within the EQ program) to determine that installed equipment meets qualification criteria. The original DC voltage calculations were unavailable and calculations performed in 1994 were done to the panel level but not to the component level. Calculations to the component level were scheduled but had not been performed at the time the violation was discovered.
Corrective Actions That Have Been Taken to Avoid Further Violations On site and off site tests were conducted to establish the voltage and in-rush current at which the solenoids would actuate the EMRVs. The plant was modified to reduce the voltage drop to the EMRVs and calculations were completed to verify that sufficient voltage would be provided to the EMRVs under all design basis conditions.
Prior to the discovery of the violation, GPU Nuclear had developed a Project Management Process to enhance design control. Also prior to the discovery of the violation, improvements had been made to the calculation process including implementation of a calculation database and a multidiscipline review of design inputs and assumptions for key calculations. These initiatives are expected to be successful in improving design control activities.
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Accountability was established for verifying that EQ parameters have been met. EQ files have been reviewed to ensure required electrical parameters have been considered.
Corrective Actions That Will Be Taken to Prevent Recurrence Applicable procedures will be revised to ensure required parameters are considered in qualifying plant equipment. EQ files will be amended to provide an assessment of
- required vs. actual electrical characteristics to assure proper qualification. Training will be conducted on the EQ process and accountabilities emphasizing the concerns related to this occurrence. DC voltage drop calculations to the component level will be completed.
All these actions will be completed by the end of the second quarter of 1999.
Date of Full Comnliance Full compliance for EMRV solenoid voltage was achieved April 2,1998 when the plant modification and voltage calculations were completed.
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