IR 05000219/1975010
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IE:I Form 12
(Jan.75) (Rev)
U. S. NUCLEAR REGULATORY COMMISSION
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0FFICE OF INSPECTION AND ENFORCEMENT
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REGION I
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IE Inspection Report No:
50-219/75-10 Docket No:
50-219 Licensee:
Jersey Central Power and Light Company License No:
DPR-16 Madinon Avonne nr Pimch Rnul nnaa Priority:
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Morristown. New Jernov 07960 Category:
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Safeguards Group:
Location:
Oyster Creek. Forked River. Nou Jernov
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Type of Licensee:
1930 MWt. BWR Type of Inspection: Routine Unannounced Dates of Inspection: _ March 25-28-31. 1975
$0l Dates of Previous Inspection:
March 25-27. 1975
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t Reporting Inspector:
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D. F. fohnson, Reactor Inspector DATE Accompanying Inspectors:
nnnn DATE DATE DATE Cther Accompanying Personnel:
None DATE Reviewed By:
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E. C. McCabe, Senior Reactor Inspector Nuclear Support Section
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Reactor Operations Branch i
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9604220358 960213 PDR FOIA DEKOK95-258 PDR
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SUMMARY OF FINDINGS
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5 [i6, Enforcement Action A.
Items of Noncompliance
.1.
Infraction Contrary'to the requirements of 10 CFR 50 Appendix B, Criterion VI, the Oyster Creek Operational Quality Assurance Plan Section V, and Technical Specifications Section'6.2.F, temporary changes to eight (8) operating procedures were not reviewed and approved.
(Detail 2)
Licensee Action on Previously Identified Enforcement Items Not inspected Design Changes Non identified Unusual occurrences
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None identified Other Significant Findings A.
Current Findings 1.
Acceptable Areas
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No noncompliance, deviations or unresolved items were identified
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in the following areas.
Procedural requirements for revising, changing and upgrading a.
procedures.
(Detail 5)
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Format and content of facility procedures.
(Detail 8)
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Authorities, responsibilities, and performance of the Plant
Operating Review Committee. ' (Detail 6)
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Unresolved Items l
i Scope of procedural coverage.
(Detail 7)
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b.
Administrative Controls of authorized management review and approval of facility procedures.
(Detail 4)
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Standing Orders.
(Detail (9)
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Facility procedure revision program.
(Detail (8)
3.
Status of Previously Reported Unresolved Items i
a.. The following data represents the status of the licensee's program for the revision and upgrading of facility procedures.
(Detail 8)
% Revised / Written
% Reviewed
% Approved
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100
5 b.
37.5% of the administrative procedures previously identified as lacking in scope of coverage with respect to Regulatory Guide j
1.33 Appendix A, remain to be completed.
(Detail (7)
i Staffing requirements for refueling has been resolved.
(Detail 3)
c.
Management Interview inop A management meeting was held at the Oyster Creek Nuclear Power Station on March 31, 1975 at the conlusion of the inspection.
Personnel in attendance Mr. J. T. Carroll, Jr., Station Superintendent Mr. J. Menning, Staff Engineer l,
Mr. D. L. Reeves, Chief Engineer Mr. D. A. Ross, Manager Nuclear Generating Stations Summary of Items Discussed 1.
Item of Noncompliance.
(Detail 2)
2.
Staffing requirements for Refueling.
(Detail 3)
3.
Procedure review and approval.
(Detail 4)
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2.
Unresolved Items Scope of procedural coverage.
(Detail 7)
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b.
Administrative Controls of authorized management review and approval of facility procedures.
(Detail 4)
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Standing Orders.
(Detail (9)
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d.
Facility procedure revision program.
(Detail (8)
3.
Status of Previously Reported Unresolved Items The following data represents the status of the licensee's a.
program for the revision and upgrading of facility procedures.
(Detail 8)
% Revised / Written
% Reviewed
% Approved 100
5 b.
37.5% of the administrative procedures previously identified as lacking in scope of coverage with respect to Regulatory Guide 1.33 Appendix A, remain to be completed.
(Detail (7)
Staffing requirements for refueling has been resolved.
(Detail 3)
c.
Management Interview OWE 0 A management meeting was held at the Oyster Creek Nuclear Power Station on March 31, 1975 at the conlusion of the inspection.
Personnel in attendance Mr. J. T. Carroll, Jr., Station Superintendent Mr. J. Menning, Staff Engineer Mr. D. L. Reeves, Chief Engineer
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Mr. D. A. Ross, Manager Nuclear Generating Stations Summary of Items Discussed 1.
Item of Noncompliance.
(Detail 2)
2.
Staffing requirements for Refueling.
(Detail 3)
3.
Procedure review and approval.
(Detail 4)
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Procedure revision and change' methods.
(Detail 5)
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Plant Operating Review Connaittee.
(Detail (6)
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Facility procedure coverage.
(Detail (7)
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Faility procedure format and content. (Detail 8)
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Standing orders.
(Detail 9)
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DETAILS
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1.
Persons Contacted (
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' Mr.;J. T. Carroll, Station Superintendent Mr. N. Cole, Shift Foreman
- Mr. C.. C. Dekker, Control Room Operator Mr. E. J. Growney, Technical Engineer
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-Mr. D. MacFarlane, Control Room Operator
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Mr. J. P.'Maloney, Operations Supervisor Mr..J. Menning, Staff Engineer
Mr. D. L. Reeves, Chief Engineer Mr. E. Riggle, Maintenance Supervisor Mr. E.-Rosenfeld, Assistant Staff Engineer
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Mr.-D. A. Ross, Manager Nuclear Generating Stations Mr. J. P.. Sullivan, Jr., Operations Engineer Mr. R. Swift, Maintenance Engineer
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2.
Item of Noncompliance 10 CFR 50, Appendix B, Criterion VI requires that measures shall be established to control the issuance of documents, such as instruc-tions, procedures, and drawings, including changes thereto, which prescribe a11' activities affecting quality.
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These measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel.
The Oyster Creek's Operational Quality Assurance Plan,Section V, states that the "0yster Creek Superintendent is responsible for en-
suring that instructions and procedures associated with the operation of components and systems are prepared, reviewed, approved and im-plemented.
This also includes the issuance of appropriate changes to such documents."
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Technical Specifications Section 6.2.F. states " Temporary changes to procedures shall be documented and subsequently reviewed by the Plant Operations Review Committee and approved by the Station Superintendent."
Contrary to the above, the inspector, through selective examination of procedures representative records and interviews with personnel determined that temporary changes to the following operating pro-cedures are in effect and-the' changed procedures have not been re-vised, documented, and reviewed by the Plant Operations Review
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Committee or approved by the Station Superintendent in accordance with the Technical Specifications.
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-5 Procedure Temporary Change Temporary Change Dates 203 " Approach to Critical" Step 22g. deleted 12/11/73 Step 23 instructions 12/11/73 c.-
E U l, to increase reactor power by rod movement or recirculation flow Step 12.b, 5, 6, 7, 8, 3/9/74 major change 203.1 Startup and Synchroni-Step 6 permits operation 11/27/73 zation of Unit above rod block setting 201.2.1 "Preperation for Adherence to switching 3/29/74 startup and shutdown" and tagging procedures temporary change not removed-revision was made 6/28/74 211.3.2.lb.2 " Power Allows operation with a 11/19/73 Operation" continuous rod block in effect 212.2 Refueling Procedures Precautions Step 4 TS 5/18/74 change 3.2.C.1 standby liquid control system no longer required 212.6 Refueling Procedure Step 11 pen and ink change '5/3/74 to reference as per TS section 3.1.1J 301.3.1 Placing Recircula-Steps 6 and 7 deleted tion Pump ir Operation 301.3.2 Removing Recircula-pen and ink change 2/18/74 tion Pumps from Service This repetitive failure to perform required review of temporary changes is considered an Infraction level item of Nonccmpliance.
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Staffing Requirements for Refueling
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The licensee stated his intention is to utilize non-licensed individuals for the manipulation of fuel handling apparatus
.e e.n 20,:
and mechanisms for the movement of fuel assemblies in and out t
of the core-during forthcoming refueling operations.
In addition, the licensee's stated intention is to provide a licensed operator in the control room for supervision of fuel'
handling activities by maintaining direct communication between the control room and the fuel handling area, without providing a licensed individual for the direct supervision at the fuel handling area.
In subsequent telephone conversations between the Office of x
Inanection and Enforcement Region I, the Division of Reactor
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Licensing, and representatives of the Jersey Central Power and Light Company resulted in a commitment from the licensee to provide a senior licensed operator on the refueling floor to directly supervise fuel handling activities.
In addition, the Division of Reactor Licensing on April 11, 1975 issued a letter to Jersey Central Power and Light Company stating their current position on staffing requirements for fuel handling activities as delineated in the Standard Techni-EMEN cal Specification, and requested that the licensee provide within 15 days their actions for compliance with these require-ments.
This item is resolved.
4.
Procedure Review and Approval The inspector performed an audit, on a sampling basis, of the following
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procedures.
101 Organization and Responsibility
107 Procedure Control 105 Maintenance, Repair and Modification Control
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113 Calibration of Installed Plant Instruments j
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607 NSSS Leak Test
'ct 608 Isolation Condenser System Test
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The inspector, based on the review of. the above procedures and the on-site safety committee meeting minutes, found no discrepancies between the licen-see's review / approval methods / procedures, the current Technical Specifica-tions, and the licensee's administrative controls.
The inspector stated that the licensee's present Technical Specifications and administrative controls do not specify any frequency for periodic review of facility procedures.
ANSI N18.7 " Administrative Controls for Nuclear Power Plant" states that,
"Each procedure shall be reviewed prior to initial use and periodically j
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thereafter. The frequency of such reviews shall be specified."
The Division of Reactor Licensing Standard Technical Specifications
Section 6.B.2 states, "Each procedure and administrative policy and changes thereto, shall be reviewed by the Facility Review Group (FRG)
i and approved by the Plant Superintendent prior to implementation and periodically as set forth in each document."
In response to the Division of Reactor Licensing's request for the
,gyg Jersey Central Power and Light Company to submit an application for
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Amendment to the Oyster Creek operating license to revise the Technical Specifications to conform to the Standard Specification on Administrative Control, the licensee submitted an application for Amendment of Facility Operating License DPR-16 which commits to the above requirments.
The licensee stated that administrative Procedure 103 is currently under revision and will incorporate the requirements for a periodic review of applicable facility procedures with a specified frequency.
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This is an Unresolved Item pending Licensing action on the proposed Technical Specifications and licensee action on the requirements involved.
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Procedure Revision and Change Methods
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The inspector reviewed administrative. Procedure 101 " Organization.
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r and - Responsibility," 107 " Procedure Control" r.nd verified that the i-
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. licensee has procedures for changing,. revising and updating facility j
!.yf y L procedures, including temporary changes.
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The inspector reviewed PORC meeting minutes for the years 1974 and j.
1975, and verified that changes and revisions to procedures resulting-
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from Technical Specification revisions, design changes, system or
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component modifications and procedure updating have been reviewed i
l and approved in accordance with.the requirements of the Technical Specifications and the licensee's administrative Controls'.
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The inspector examined, on a sampling basis, the control room copies
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of operating and emergency procedures and verified that these pro-l v.
cedures being utilized for the operation of the facility were the
I latest revision and were properly reviewed and approved by authorized nanagement.
The inspector had no further questions on these items.
6.
Plant Operating Review Committee
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The inspector performed a sampling audit of the PORC meeting minutes'and verified that the following items were in accordance with the requirements of the Technical Specifications, the licensee's administrative controls,
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a.
Committee membership.
b.
Meeting frequencies.
c.
Quorums.
d.
Responsibilities, e.
Authorities.
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Records.
g.
Committee evaluations and recommendations.
h.
Organizational membership.
The inspector had no further questions in this area.
7.
Facility Procedural Coverage Based upon' review of procedure indices, examination of records, and discussions with the licensee, the inspector questioned the facility procedure coverage scope.
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-9-Examples of areas with questionable coverage include, but are not limited to, the following.
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Administrative Procedures rW ht))
(1) Authorities and responsibilities fe safe operation and
shutdown.
(2) Record retention.
(3) Recall of standby personnel to the plant.
b.
Emergency Procedures (1) Fire in Contol Room or forced evacuation of control room.
The licensee stated he would initiate or revise existing procedures to include procedural coverage for the above items.
This is an un-unresolved item pending implementation of licensee action.
8.
Facility Procedure Format and Content A.
The licensee has instituted a program for the review of all facility procedures for the purpose of upgrading and revising to comply with the format and content recommended in ANSI N18.7.
The following is a status of completion of this program.
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% Revised /
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% Fully Procedures Written Reviewed Approved 1.
General Plant Opera-100
0 ting Procedures (200 series 8 procedures)
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System Operating Pro-100
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cedures (300 series 57 procedures)
3.
Nuclear Instrumentation 100 100
Procedures (400 series 8 procedure)
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Emergency Procedures 100
0 (500 series 33 pro-cedures)
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% Revised /'
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% Fully Procedure Written Reviewed Approved
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Surveillance Pro-100
2 cedures (600 series
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84 procedures)
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Maintenance Pro-100'
4 cedures (700 series 85 procedures)
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Core Procedures (1000 100
26 series 27 procedures)
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100% revised and written 56% final review 5% final approved
This number does not include the Chemistry and Radiation Protection procedures that are being reviewed and revised in house and therefore are not part of the overall program status.
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B.
The inspector conducted an audit of the facility procedures program by a sampling review of the following revised procedures.
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Administrative Procedures 101 Organization and Responsibility.
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105 Maintenance, Repair and Modification Control.
c.
107 Procedure Control.
2.
Operating Procedures 301 Nuclear Steam Supply System.
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304 Standby Liquid Control System, 308 Emergency Core Cooling System.
c.
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311 Fuel Pool Cooling System.
317 Reactor Feedwater System.
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329 Reactor Building Heating Cooling and Ventilation System.
g.
334 Instrument, Service, Breathing and Bleeder Check Air Systems.
h.
406 Process Radiation Monitoring System.
3. -Emergency Procedures a.
503 Instrument Air Failure, b.
519 Loss of Containment Integrity.
c.
504 Service Water Failure.
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Maintenance Procedures 704 Reactor Vessel Steam Dryer and Separator Removal
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and Replacement.
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705 Control Rod Drive Removal and Replacement.
708 Reactor Recirculation Pump Rotating.
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d.
719 Shutdown cooling Pump Rotating Assembly Removal and Replacement.
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Alarm Procedures a.
515 Steam Leak.
b.
522 Inadvertent Poison Injection.
501.4.1 Containment Spray.-
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501.4.2 Feedwater low flow.
The inspector stated that the format and overall content of the revised procedures is consistent with the requirements of the Technical Speci-fications and is in accordance with the guidelines set forth in ANSI N18.7.
.NIAIIB The inspector had no further questions in this area.
Until the licensee completes this program and performs final approval and implementation of the procedures this remains as an unresolved item to be followed in subsequent inspections.
9.
Standing orders The inspector reviewed, on a sampling basis, the control room standing orders that provide supplemental instructions to the operators for operation of systems and components determined by management to be of-sufficient significance to warrant highlighting and additional guidance.
The inspector identified the following items as a result of his review, Alarm setpoints and safety related operating limits contained in a.
the standing orders are in conflict with the parameters stated in the operating procedures.
In discussions with the' licensee's operating personnel they displayed an uncertainty as to which was the correct value.
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b.
The inspector identified particular standing orders containing instructions, Technical Specification limits and operational limits related to nuclear safety.. Based on item b. this infor*-
mation and guidance contained in standing orders must be reviewed and incorporated as applicable into existing facility procedures
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and subsequently approved by authorized management in accordance
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with the ischnical Specifications.
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The licensee concurred with the inspectors comments and stated that a review of standing orders will be performed and adminis-trative procedures will be revised to delineate review and approval of atanding orders.
In addition, standing orders will
be phased oot and incorporated into existing facility procedures
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as applicable.
Until the licensee completes his proposed actions, this is an unresolved item.
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