ML20248D344
| ML20248D344 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 05/20/1998 |
| From: | Roche M GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1940-98-20272, 50-219-98-04, 50-219-98-4, NUDOCS 9806020397 | |
| Download: ML20248D344 (5) | |
Text
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GPU Nuclear,Inc.
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U.S. Route #9 South Post Office Box 380 NUCLEAR rorked Rwer, NJ 08731-0388 Tel 609-971-4000 May 20, 1998 1940-98-20272
- 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 98-004: 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.
If you should have any questions, or require further information, please contact Brenda DeMerchant, Oyster Creek Regulatory Affairs Engineer, at 609-971-4642.
Very truly yours, Q.g Michael B. Roche
' Vice President and Director Oyster Creek MBR/BDE/gl Attachment cc:
Administrator, Region 1
. NRC Project Manager g
NRC Sr. Resident Inspector l
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Attrchment 1 IR 98-004 Response to Notices of Violation Violation i 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 Isolatiou Condensers is from the Demineralized Water Transfer System," a normally non-radioactive system.
l Contrary to the above, since initial plant operation (1969), operators implemented 1
Procedure 307, Isolation Condenser System (ICS), which permitted fill and make up to the isolation condensers during normal plant operations, when the system was in Standby, by a means other than the Demineralized Water Transfer System (DWTS). 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).
Response
GPUN concurs with the violation as stated.
Reason for Violation:
Several years ago, the Isolation Condensers were drained to suppon internal inspections and preservation as part of refueling outage activities. At that time, the System Operating Procedures were revised to refill the Isolation Condensers using Condensate Transfer which is the installed makeup source for operational use. Additionally, this revision included an option to use Condensate Transfer for evaporative losses. During that time period, safety reviews did not include as rigorous a review of the FSAR and other
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Licensing Bases Documents as is presently performed. As such, it was not identified that the FSAR specified that Demineralized Water would be used for evaporative makeup.
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IR 98-004: Response to Notices of Violation Page 2 Since the plant's original configuration does not provide for any permanent connections for Isolation Condenser makeup from the Demineralized Water Transfer System, the operators failed to recognize this inconsistency with the FSAR and thought that it was acceptable to use Condensate Transfer for evaporative losses. Furthermore, the operators have been required to makeup to the Isolation Condenser more frequently than they normally would for evaporative losses due to inadequate seating of the Condensate Return Valve. Since the Demineralized Water Transfer System requires the installation of a temporary modification and can not be controlled from the Control Room, the operators did not consider Demineralized Water Transfer as the preferred makeup source.
Corrective Steps That Have Been Taken:
Upon discovery of this inconsistency, Operations Management prohibited usage of Condensate Transfer as the makeup source for evaporative losses.
The Corrective Steos that Will Be Taken to Avoid Further Violations:
A revision to the System Operating Procedure has been developed and is in final review.
This revision incorporates adequate controls to assure the makeup to the Isolation Condensers is from the Demineralized Water Transfer System while in standby (evaporative losses).
Date of Full Compliance:
Full compliance will be achieved when procedure is approved. This action is scheduled to be completed by the end of May,1998.
Violation 2 Section 6.8.4.a.3 of Technical Specifications (TS) requires that a radioactive emuent controls program shall be provided and include " Monitoring, sampling, and analysis of radioactive liquid and gaseous emuent 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 appropriate, surveys of radiation levels in unrestricted and controlled areas and radioactive materials in emuents 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.
Contrary to the above requirements, at least since December 1996, the licensee's radioactive emuent 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).
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IR 98-004: Response to Notices of Violation Page 3 l
Response
GPUN concurs with the violation as stated.
- Reason for Violation:
While developing our 1997 Annual Emuent Report, we recognized that the release
. pathway from the Isolation Condensers had to be included because ofincreased tritium levels. Due to an incease in the evaporative losses from the Isclation Condensers, the contribution from this pathway was greater than previous years. Recently, we identified an increase in the tritium concentrations of our primary coolant systems that has subsequently been attributed to control rod blade leakage. Although this increase was significant with respect to previous triticm levels, it is still well below any specified limits. Since evaporative makeup to the Isolation Condensers was switched to Condensate Transfer, the increased tritium concentrations and evaporative losses resulted in a greater contribution to our emuent releases than previously considered. Although individual sections within our organization had the necessary information to identify this issue sooner, a lack of communications between departments and the absence of a single "emuent monitoring authority" delayed this realization. As such, we failed to recognize this potential pathway when developing our previous Annual Emuent Reports.
Corrective Steps That flave Been Taken and the Results Achieved:
Organ dose and whole body dose calculations were performed using this release pathway and reported in the 1997 Annual Emuent Report. The calculations show that a regulatory limit was never exceeded nor approached.
Because'of the potential release pathway, monthly samples ofIsolation Condenser shell water for tritium have been added to the chemistry schedule. In addition, actions are underway to evaluate other potential release paths for the impact ofincreasing tritium levels.
The efiluent doses from the isolation condensers for 1995 and 1996 have been calculated and the emuents for 1997 have been recalculated. The calculation shows that the tritium from the ICs would have added 3.6 % to the maximum individual organ dose in 1995 and 6.2% in 1996; therefore, the Annual Emuent Reports for those years do not require revision. The calculations also confirmed that the reported tritium efIluent from the ICs was overestimated in 1997 by almost a factor of two.
Doses for 1997 were reduced to about 2/3 of those originally reported in the 1997 EfIluent Release Report. A revision to that report has been prepared and will be submitted prior to May 31,1998.
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l IR 98-004: Response to Notices of Violation Page 4 Corrective Steps That Will Be Taken to Avoid Further Violations:
Condensate transfer will be used for surveillance requiring its use (Inservice Testing) and Isolation Condenser initiation evolutions and will not be used as the nominal mak.e-up source for evaporative losses.
Demineralized water will be used to make up for normal evaporative losses. In addition, evaporative losses will be tracked using an integrator thereby providing for a more accurate estimate of tie potential dose contribution from this source.
During the upcoming refueling outage, efforts will be made to repair the seat on the isolation condenser condensate return valve and to replace those control rods which are the most likely source of the increasing tritium concentration.
Additionally, actions are ongoing to establish a more formal interdepartmental effluent system performance team. This should be in place by June 30,1998.
Date of Full Comnliance:
When this situation was recognized, we administratively suspended usage of Condensate Transfer for makeup to the Isolation Condensers for evaporative losses. Additionally, we're monitoring routine makeup and usage to ensure that any releases via this pathway are appropriately included in our Annual Efiluent Repons.
Currently, Oyster Creek is in full compliance with the ODCM and all other Licensing Bases Documents.
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