ML20067B975

Responds to NRC Violations Noted in Insp Rept 50-219/88-02.Corrective Actions:Initiated Standby Gas Treatment Which Significantly Reduced Intrusion of Outside Air

ML20067B975
Person / Time
Site:	Oyster Creek
Issue date:	03/30/1988
From:	Fiedler P GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20067B960	List: ML20067B975
References
NUDOCS 9102110135
Download: ML20067B975 (6)

Text

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GPU Nuclear Corporation MNuclear

= a88 Forked River, New Jersey 08731038B 609 9714 000 Writer's Direct Dial Number:

Drch 30,1988 U.S. Nuclear Regulatory Comission Attention: Document Control Desk

' Washington, DC ' 20555

Subject:

Oyster Creek Nuclear Generating Station Docket No. 50-219 IE Inspection 50-219/88-02 Response to Notice of Violation In accordance with 10CFR2.201, Enclosure A provides GPUN's response to the Notice of Violation contained in IE Inspection Report 50-219/88-02. GPUN does not concur with Violation A. GPUN does concur with Violation B.

In addition to the Notice of Violation, the NRC staff has requested additional information concerning low temperature in the reactor building.

This request represents a significant effort within a short period of time to address the broad scope concerns identified in the staf f's request. In relation to.this event,'GPUN submitted on February 25, 1988 Licensee Event Report No.88-001 and, enclosed herein, a response to the-Notice of Violation. These submittals describe GPUN's evaluation of the event and detail extensive actions being taken to-address both GPUN's and NRC's concerns, including continuing evaluations. Immediate actions have been taken to prevent recurrence.of this event and evaluations of broader scope have been initiated.

GPUN's response to violation B discusses those actions taken with regard to the biennial procedure review process. Licensee Event Report (LER)88-001 identifies additional . action being taken to upgrade procedures and evaluate long term consequences with regard to structures and systems. Temperature limitations discussed in the updated FSAR are being reviewed in conjunction with the evaluation being conducted.

As in the past, the results of GPUN's continuing evaluations will be made available to NRC inspection personnel. A premature, accelerated effort to further respond to the staf f's request for information, with attendant' commitments as requested, will not serve to benefit plant safety. The actions taken to date have achieved compliance with the regulation and assure the continued safe operation of the Oyster Creek Station.

-9102110135 910131 PDR ADDCR 05000219 G PDR GPU Nuclear Corporahon is a subscary of !ne General Pubhc Utilities Corporation

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-RE: NOV-INSPECT 20N 88-02

.PAGE-TWO If you should have any questions, please contact Mr. George W. Busch of our Licensing Department at (609)971-4909.

Very truly yov s, K A. ] '), 3  ?

P M iedT[r

" ice President and Director '

-0yster Creek PBF/GB/dmd ,

Enclosure (0449A) cc: Mr. William T. Russell, Administrator Region.I ,

U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-Mr. Alexander W. Dromerick, Project Manager

- U.S. Nuclear Regulatory Commission Division of-Reactor Projects I/II Washington, DC 20555 NRC Resident Inspector Oyster-Creek Nuclear Generating Station Forked River._ NJ 08731' I

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ENCLOSURE A Response to Notice of Violation i Violation A:

i The Code _ of Federal Regulations 10 CFR 50.59 permits licensoer. to nake changes in the facility as described in the safety analysis report provided a written safety evaluation is performed which provides the bases .

for the determination that the change doc:; not 4nvolve an unreviewee l safety question. Station Precedure 125, Conduct of Plant Engineering,

- Section .6.& requires written safety evaluations per 10 CFR 50.59(a) for any change to the plant confVguration whether or not the item is considered nuclear safety-related.

Contrary to these requirements, on January 27, 1988, it was detenained no written safety evaluation was perfortled ()r other compensating ooerationa or. design measures implemented for tt:e inoperative condition of the reactor > building heating syste.n relative to its des'gn basis documented in

the updated FSAFl.- This condition,.'outside of the (fesign basis, was permitted.to exist.for approximately two years.

Pesponse:

GPUN does not concur in this violation.

'The_ low temperatures nxperienced in the reactor building were a result of inoperability of the steam heating coil in the building heating and ventilation system.- This event was exacerbated by'a rebalancing of the reactor, building ventilation system which had been accomplished prior to this event. - Freezing of the! instrument lines occurred in a location where

-air flow from a supply duct was channeled around the: lines which froze.

Due to the system rebalancing, the supply air flow had.been increased resulting in- higher' air' flows in the lower _ levels of the shutdown cooling area. LAs: discussed in the . inspection report, immediate actions where .

o taken to initiate standby gas treatment'which significantly reduced.the

intrusion.of outside-air. Subsequent actions taken were to establish ,

periodic ' monitoring of building temperatures and to repair the- steam heating coil'.

- As.a: result of additional- review of this event, it was determined that Inoperability of the steam heating coil was partially due to-a misinterpretation of maintenance test data during the period in which the

_ plant was being prepared for cold weather conditions. GPUN has initiated engineering evaluations for the Heating s - Ventilation System, _ structural

- and equipment temperature-limitations, and a review of the proced.ures for l

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2 cold tosnilinaa. The cold weatit'.r oresaration plan for Oyster Creek is Selag reviewrA nnd revised to assure that adequate measures are taken to prepan I.'n stu+;en for low temperature <onditions. Operating procedures bave' alsc been rav f oNed and revised where necessary to correct de'fc.14 redes rxlatt4 to cold weather conditions and to assure the procedures ars accutute and appropriate with regard to limits and i astrumenta tion.

The cited regulation,10 CFR 50.59, allo-s the liccosee to make changes or conduct tests and experiments without prior NRC approval provided such evaluations do not involve a change to the Technical Specifications or an unreviewed safety question. The sole purpose of this evaluation is to determitt if a proposed change, test, or experiment requires NRC aoproval j prior to implementation, y The inoperability of steem heating coils in the Reactor Buildf 7g Ventilatien System was a result of mechanica3 deficiencies and there was never any intent to.clange the configuration or operation of the system.

l Therefore,10 CFR 50.59 is not applicable.

Additscnally, the dqsign bases of the Reactor Buls'cIng V:ntilation iy1+,','

is stated in the Ib4.ated FSAR, Section 9.4.2.1 entitled " Design Bases,"

In this section the design objectives are stated as: )

1. To provide a controlled environment so that the maximum allowable ambient temperature for standard rated electric 61 '

equipment (104*F) is not exceeded; and

2. To regulate the static pressure within certain areas nf the k plant so as to minimize the spread of airborne radioactivo contaminants from contro119d to uncontTolled areas and to provide safe 6isposal of 61rt.orite contaminants.

The dssign bases also states that the HVAC systems were designed to cope wit.1 a minimum temperature of 10*F (drybulb). The design bases recognizes that low :emperature conditions would be exceeded 2.5 percent of the time. Therefore, nothing in the design basis requires that reactor building temperatur9 be maintained at any minimum temperature, only that the temperature never exceed 104*F.

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- . . 3-Violation 8: *

• Technical Speification 6.8.1, specifies that written procedures shall be maintained. Station Procedure 107, Procedure Control, Section .3.3.4 requires a periodic review of procedures be conducted once evf#y two years. This review is defined as a documented reading of the procedures to assure it continues to satisfy its objective in a manner consistent with plant requirements. In addition, the reviewer should contact a

" user" of the procedure (cperator, technician, etc.) for feedback on adequacy of the procedure.

Contrary to the abon, a review of Station Procedere 329. Reactor Building Heating, Cooling, and Ventilation System, on January 29, 1987 indicates that inadequate procedural reviews have been conducted in that Step 2.3.6 describes a reactor building temperature indicator on Panel 11R in the control room. This temperature indicator appears never to have been installed, consequently the procedural error appears to have existed for approximately twenty years.

Responsel GPUN concurs with the viointion.

Plant operating procedures are revised as a result of modifications, technical specification changes, errors identified by users, or errors identified during the biennial _ review. The error in station procedure 329, " Reactor Building Heating, Cooling, and Ventilation System," was not identified during any of these reviews. During initial plant design, it was planned to provide the instrumentation referred to in the procedure, however, during construction this instrumentation was eliminated. Since then, subsequent reviews of the pr0cedure failed to identify the discrepancy. ,

Subsequent to the violation,, operating procedures were reviewed to determine the extent of similar procedure errors. A Group Shift Supervisor, a Group Operating Supervisor, and three Control Room Operators reviewed all 200 and 300 series procedures related to operating the turbine and reactor plants, Their intention was to (1) Identify ilmits that were inappropriate, unsupported or clearly not maintained; and (2) to identify procedures that could not be executed due to references to equipment that does not. exist in the plant. Two instances related to limits arid two related to equipment were found and are being corrected.

The last biennial review of procedure no. 329 was conducted in January, 1987. Since then, in-July 1987,- station procedure 107 was revised to include contacting the user of the procedure to obtain feedback on the adequacy of the procedure. -As of leech 2, 1988, Operations' proceduros will be reviewed by the user of the procedure. This will significantly improve the biennial procedure review process.

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i Since operation of the Oyster Oreek plant began, major improvements to the safety review process, plant modification procedures, and periodic review requirements have emphasized requirements covering review of procedures as ,

an integral part of these reviews. Operational experience to date indicates there are no niajor problems in the area of procedural adequacy.

Where errors or needed reviews arc identified, procedures are updated as necessary.

In response to this event, GPUN will issue additional guidance, including ,

a discussion of this event to departmental Managers re-emphasizing review  ;

responsibilities . Additiona!. guidance to reviewers will be included in  :

Station Prscedure 107 which.wili re-enforce the need to obtain user feedback dttring the biennial reviews of procedures. '

s Full compliance was achieved on March 2,1988 cv revising procedure 329 to delete reference to the reactor buildf ng tempe. ature instrument. ,

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