ML20236R352

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Responds to NRC Re Violations Noted in Insp Rept 50-219/97-10.Corrective Actions:Operations Mgt Has Instructed Operations Personnel to Comply W/Requirements of TS 3.1.B.3
ML20236R352
Person / Time
Site: Oyster Creek
Issue date: 07/15/1998
From: Roche M
GENERAL PUBLIC UTILITIES CORP.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-219-97-10, NUDOCS 9807210399
Download: ML20236R352 (3)


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l GPU Nuclear, Inc.

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U.S. Floute #9 South NUCLEAR Post Of*:ce Box 388 Forked River, NJ 08731-0388 Tel 609-9714000 July 15,1998 1940-98-20404 U. S. Nuclear Regulatory Commission l

Attn: Document Control Desk Washington DC 20555

Dear Sir:

Sutiject:

Oyster Creek Nuclear Generating Station Docket No. 50-219 Inspection Report 97-10 Reply to a Notice of Violation By letter dated February 8,1998, the NRC docketed Inspection Report 50-219/97-10.

Appendix A to that Report contained Violation 97-10-02. By letter dated March 31,1998, GPU Nuclear, Inc., contested this violation. In response, by letter dated June 16,1998, the NRC denied the withdrawal of this violation. Attachment I to this cover provides the requisite reply to the previously contested violation.

If any additional information or assistance is required, please contact Mr. John Rogers of my staff at 609.971.4893.

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Very truly yours,

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pgichaeTIL Roche e

Vice President and Director

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. v Jg Oyster Creek

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l MBR/JJR Attachment cc:

Administrator, Region I

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NRC Project Manager j

i Senior Resident Inspector 9907210399 990715 '

PDR ADOCK 05000219 G

PDRL h

.b NRC Notice of Violation 97-1042 l-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 tripped condition whenever all three of the following conditions exist:

Reactor power is greater than 35%

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.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 L

with more than one bypassed or failed LPRM detector on the same axial level as the bypassed or failed detectors specified in (2) above.

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. 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 required testing.

L GPUN Reply To Notice Of Violation 97-10-02 i

GPUN concurs with the violation as written.

L Even though GPU Nuclear had always believed that the LPRM Calibration was an integral activity for ensuring operability of the APRM Monitoring System, w-have reviewed your letters and acknowledge that a violation occurred, based on your understanding of the requirements.

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r 1940-98-20404 Attachment I l

Page 2 l.

Reason for the Violation When the Oyster Creek Technical Specifications were revised to address the power oscillation and instability concerns, GPU Nuclear did not recognize the full extent of these requirements.

The routine LPRM adjustments and calibrations should have been added to applicable sections L

of the Technical Specifications.

Corrective Steps Taken and Results Achieved.

- Operations Management has instructed ' operations personnel to comply with the requirements of Technical Specification 3.1.B.3 when performing the monthly LPRM calibrations or bypassing an APRM channel for any other purpose than routine gain adjustment or surveillance specified in the Technical Specifications.

Additionally, Operations Management has distributed the NRC Inspection Report and your response to our original position to the Operations Supervisors in order to heighten their awareness and sensitivity to this issue.

Corrective Steps to be Taken to Prevent Recurnnce Operations Management will review our revised understanding of this Technical Specification, and reinforce management's expectations and standards regarding compliance during the

- upcoming Licensed Operator Requalification training cycle, currently schduled to be completed by September 11, 1998.

Operations Management will review and revise the LPRM adjustment and calibration procedures as appropriate to enhance the existing guidance provided to the operators regarding the requirements of the Technical Specifications. This review will be completed by September 30,1998. Any required procedure revisions will be completed by November 30,1998.

1 GPU Nuclear will review the Oyster Creek Technical Specifications and submit a revision (as appropriate) to include the routine LPRM adjustments and calibrations as Technical Specification required surveillance, thereby exempting these activities from the requirements of Technical Specifications 3.1.B.3. This review will be completed by September 30,1998.

Date When Full Compliance was Achieved Full compliance was achieved at 10:58 PM on February 21,1995, when APRM Channel 5 was unbypassed and returned to service.

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