ML20133D353

Responds to 850618 Request to Elaborate on Discrepancies in Plant Drawings.Adequate Insp,Engineering & Mgt Resources Assured Time to Repair Discrepancies

ML20133D353
Person / Time
Site:	Oyster Creek
Issue date:	07/08/1985
From:	Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Asselstine NRC COMMISSION (OCM)
Shared Package
ML20133D358	List: ML20133D353 ML20133E461
References
NUDOCS 8507220168
Download: ML20133D353 (6)

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! MEMORANDUM FOR: Comissioner Asselstine i FROM: William J. Dircks Executive Director for Operations

SUBJECT:

OYSTER CREEK i

f This is in response to your request of June 18, 1985 to elaborate on the dis-

{ crepancies in the Oyster Creek Plant drawings. >

1 l Region I has been performing the final closeout inspections for a number of IE i Bulletins for the last two years with Oyster Creek being the last plant to be j inspected. This announced inspection (50-289/85-14) was conducted Ma i 17, 1985, at both the GPUN Corporate Office (Parsippany, New Jersey) and aty the 14 to

! Oyster Creek site. The inspection revealed that adequate documentation was not 4

readily available to confirm that appropriate inspections and analyses had been i

performed during 1979 and 1980 in response to IE Bulletins 79-02, " Pipe Support i Baseplate Designs", and 79-14. " Seismic Analysis For As-Built Safety-Related Piping Systems". It should be noted that at that time Jersey Central Power and .

i Light Company (JCP&L) owned and operated the Oyster Creek Facility. GPUN did  !

not assume responsibility as the licensee for Oyster Creek until January 1, 1982.

j Based upon the poor preliminary results, a management meeting was conducted

! with the licensee on May 20, 1985 to discuss discrepancies identified by Region I and contractor inspectors in the documentation and in the small portion of plant systems directly inspected by the NRC. GPUN committed to embark on a detailed review of the as-built condition of the plant piping systems important to safety and provide a status of this review within three weeks. It was acknow-ledged by GPUN that portions of the JCP&L files were being located and these l were responsive to the inspector's needs but not yet fully assembled.

At the second Management Meeting held at Region I on June 13, 1985, the results

. of the review regarding the as-built conditions were discussed and GPUN ac-knowledged that most of the JCP&L records of the subject inspections had not

. been incorporated into their record system for the plant.

l The principal elements of their review and inspection program including screen-

' ing criteria, were discussed along with the engineering analysis and disposi-tion of the nonconformances resulting from the Quality Control inspections to l date. GPUN stated that, although a number of deficiencies exist in the records, i evaluations, and plant installations, their overall evaluation thus far con-

! firmed the correctness of the original design. Since the plant was shut down just previous to the meeting for an unrelated reason, the extent of r inspection activities that could be conducted in the drywell during this period

! . were also discussed. The licensee comitted to perfom inspections of the 8507220168 850708 PDR CDPMS NRCC

] CORRESPONDENCE PDR I

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Comissioner Asselstine 2 accessible portions of several key systems during the duration of the shutdown.

The licensee was instructed to provide a Justification for Continued Operation (JCO) before comencing a restart. The GPUN response was provided June 14, 1985 and is attached. Based upon the outcome of the June 13 meeting, the JC0 '

and the resident inspector's onsite confirmation of results, the staff agreed to the Oyster Creek restart.

Subsequently, on June 25, 1985, Region I and NRR staff visited the GPUN corporate offices to verify the underlying bases for the GPUN program. Based upon the detailed examinations, GPUN was found to have recovered and assessed the JCP&L documentation that was not previously available in that the conclu-sions an( bases for the licensee's effort were confirmed.

A number of discrepancies were repaired as they were discovered in the course of their program. None resulted in the need for declaring any of the affected systems inoperable. The staff concluded that adequate GPUN inspection, engi-neering and management resources were involved to assure timely completion of the effort.

The Region I and NRR staffs have been actively involved in this issue since its discovery in mid-May, have concluded the licensee's JC0 has a valid technical basis and that the GPUN corrective actions are appropriate.

(Signes William J.Direkt William J. Dircks Executive Director for Operations

Attachment:

GPUN letter dated June 14, 1985 cc w/ attachment:

Chairman Palladino Comissioner Bernthal Comissioner Zech SECY OPE OGC J. M. Cutchin I

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Commissioner Asselstine 3 Distribution:

J. Roe T. Rehm V. Stello G. Cunningham J. Taylor EDO 000736 T. Murley J. Allan R. Starostecki S. Ebneter H. Kister E. Conner W. Bateman Docket No. 50-219 Public Local Document Public Room Document Room (PDR) (LPDR)

Region I Docket Room ED0 r/f HDenton i

RI:DRP RI:DRP RI:DRP RI:RA ED0////

Conner /sm Kister Starostecki Murley ks 7/5/85 7/&/85 7/ %f85 Dirg/85 7/g 7/$/85 e i

07/01/85' 19:06 tRC REG 1 FC.008 004

- Attachment GPU Nuclear Corporation

h. M M7 100 Interpace Parkway Pers opany. New Jersey 070541149 '

(201)263 6500 TELEX 136 482 Writer's Direct Dial Number:

201-299-6797 June 14,1985 Dr. Thomas E. Murley, Administrator Region 1 U.S. Nuclear Regulatory Comission 631 Park Avenue King of Prussia, PA 19406

Subject:

Oyster Creek Nuclear Generating Station Docket No. 50-219 Preliminary Response to IE Inspection 85-14 During IE Inspection 65-14, several discrepancies between drawings which were updated as a result of IE Bulletin 79-14, and the inspector's field

2::r :tS.: Mere Matified. At a meeting with members of your staff on May 20,1955, we committed to reinspect those systems accessible during operation to ascertain the extent that drawings reflect actual field conditions and determine if seismic analyses, which were based on these drawings, were still valid. On June 13, 1985, we presented our preliminary results of that reinspection. This letter complies with your request that we provide a written response outlining the bases for continued operation of the Oyster Creek Nuclear Generating station untti the reinspection is completed.

We have concluded that the major techriical requirements of IE Bulletin 79-14 have been addressed and satisfied through a review of documentation relating to the 1979/1900 inspection. This docunentation review has detertnined that seismic concerns were addressed and corrected during the 1979/1900 effort.

L k l C 1'd },'

GPU Nuclear Corporation is a sues.oiary of GeneralPuboc Utstities Corporation

07/01/95^ 10:07 mC REG 1 ND. 0M 005 Dr. Thomas E. Murley June 14,1985 Page Twc With regard to IE Bulletin 79-02, our review of the existing documentation has concluded that the technical requirements of the Bulletin such as base plate flexibility, factor of safety, cyclic loads and load testing have Men addressed and show evidence of being satisfied. The existing test results will be summarized and statistics developed to document confidence levels.

The 1979/1980 inspection contained all the attributes required by IE Bulletin 79-14. The 1985 inspection included all the required 75-14 attributes plus additional attributes which surpass the requirements of the bulletin. Based on our 1985 inspection results, as of June 13, 1985, we have seen numerous minor deviations from the engineering drawings, primarily with -

regard to hangers. Many of these nonconformances are being corrected as they are found and the remainder are being evaluated by engineering for impact on system seismic capability. An engineering assessment is being performed in two steps. Each Material Nonconformance Report (MNCR) is first individually evaluated for conditional release. A system reevaluation is then conducted in order to assess the aggregate effect of all the MNCR's issued against that ,

system. No variances have resulted in any safety related system being declared inoperable. The 1985 inspection effort, as of June 13, 1985, '

confirms Bulletin 79-14 conclusions reached in 1979/1980, and it does not change our conclusions about the overall seismic acceptability of the affectea piping systems.

Because of the plant trip on June 12th, we are now in the process of performing inspections in the drywell. As of today we would expect to complete the 79-14 inspections of the accessible portions of one Main Steam Line, one equivalent Recirculation Piping Loop, one Fain Feedwater line, and one Core Spray Line. We will continue to inspect until the plant is ready for restart. Very preliminary inspection results from within the drywell, current as of June 14th, show a much reduced number of deviations between inspection .

attributes and drawings. No significant or major defects have been found to da te. The reinspection effort will he completed during our next scheduled outage of October,1985. If system reanalysis is required, the results will be reported to you as they becone available.

i In 1978 and 1979, a probabilistic risk analysis of the Oyster Creek Nuclear Generating Station was performed. This analysis, entitled the "0yster Creek Probabilistic Safety Analysis" (OPSA) estimated earthq akes of 0.229 or greater to have a mean frequency of approximately 1.15 x 10 /yr. The OPSA

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• 07/01/85' 10:08 WC REG 1 NO.008 006 1

Dr.' Thomas E. Murley, Administrator June 14,1985 Page Three study calculated a core melt frequency of approximately 1.5 x 10-4/yr for all seismic related events and approximately 2.6 x 10-0/yr due to seismic-induced LOCAs (seismic pipe breaks which is the 79-14 issuc). This equates to approximately 2% of the seismic core melt frequency, and is about 1% of the total core melt frtquency. This results from the relatively high seismic capacities of the piping systems.

In summary, our bases for concluding there is reasonable justification for continuing Oyster Creek operation pending final completion of the inspections are as follows:

1. Inspection to date as previously noted does not change the prior 1979-1980 ef fort on Bulletin 79-14. Hence we conclude the seismic piping design capability is valid.

2. Very preliminary inspection results from within the drywell . -current as of June 14th, show a much reduced number of deviations between inspection attributes and drawings. No major defect has been found.

3. The probability of a design bases or more severe earthquake prior to the completion of 79-14 inspection activities, is extremely remotc.

4. The PRA studies show seismic induced LOCA's to be a very small contribution to core melt frequency and inspection results do not channe this assessment.

It is our conclusion from all of the above that there is no perceptible change in any seismic induced LOCA risk which would affect public health and safety due to the continued operation of Oyster Creek.

Very truly yours, s"B. M P. R. Clark President pRC:kh .

0534U cc: Mr. John A. Zwolinski, Chief Operating Reactors Branch No. 5 U. S. Nuclear Regulatory Coamission Washington, DC 20555 NRC Resident Inspector Oyster Creek Nuclear Generating Station Forked River, N. J. 08731 0534U

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EDO PRINCIPAL CORRESPONDENCE CONTROL FROM: DUE: 07/01/85 EDO CONTROL: 000736 DOC DT: 06/18/85 COMMISSIONER ASSELSTINE FINAL REPLY:

TO:

DIRCKS FOR SIGNATURE OF: ** PRIORITY ** SECY NO:

EXECUTIVE DIRECTOR DESC: ROUTINO:

OYSTER CREEK DIRCKS ROE DATE: 06/19/85 U N& !* } REHM ASSIGNED TO: M CONTACT: DEMTON

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STELLO MURLEY OCUNNINGHAM SPECIAL INSTRUCTIONS OR REMARKS: TAYLOR RECEIVED NRR: 06/19/85 gACTION:,r -- _7DLrTHOMPSONa-"?

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