IR 05000219/1987017

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Insp Rept 50-219/87-17 on 870511-15.Major Areas Inspected: Licensee Action on Previous Insp Findings,Surveillance Activities & Inservice Testing of Pumps & Valves
ML20235H147
Person / Time
Site: Oyster Creek
Issue date: 07/01/1987
From: Bissett P, Blumberg N, Denise Wallace
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20235H131 List:
References
50-219-87-17, NUDOCS 8707150030
Download: ML20235H147 (11)


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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No.

50-219/87-17 Docket No.

50-219 I

i License No.

DPR-16 Licensee: GPU Nuclear Corporation

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Oyster Creek Nucleat Generating Station P.O. Box 388 Forked River, New Jersey 08731 j

i Facility Name:

Oyster Creek Nuclear Generating Station I

Inspection At:

Forked River, New Jersey l

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Inspection Conducted-May 11-15, 1987 i

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Inspectors-g~Nj#X /dce

7-( - 67 P. H. Biss6tt,~ Reactor Engineer, DRS date

&W W/bc 9-/-89 D. T. Wallace, Reactor Engineer, DRS date I

Approved by: d-

[A 7-/-M N

N. J. Bl umbe rg, Cl/i e f date Operational Programs Section Operations Branch, DRS Inspection Summary:

Routine, unannounced inspection on May 11-15, 1987 (Report No. 50-219/87-17)

Areas Inspected:

Routine unannounced inspection of licensee action on previous inspection findings, licensee surveillance activities, and the inservice testing of pumps and valves.

Results: No violations were identified.

B707150030 070707

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PDR ADOCK 05000219

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DETAILS 1.

Persons Contacted i

1.1 GPU Nuclear Corporation J. Barton, Deputy Director,' Oyster Creek P. Crosby, Supervisor, Operations Engineering V. Foglia, Preventive Maintenance Programs Manager J. Maloney, Manager, Plant Material D. Robillard, Quality Assurance Lead Auditor

J. Rogers, Licensing Engineer

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A. Rore, Plant Engineering Director

B. Shumaker, Plant Operations Supervisor 1.2 U.S. Nuclear Regulatory Commission i

W. Bateman, Senior Resident Inspector J. Wechselberger, Resident Inspector i

The inspectors also held discussions with other licensee personnel

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during the course of the inspection, including operations,

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maintenance, engineering and administrative personnel.

All individuals listed above were present at the exit meeting conducted on May 15, 1987.

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Licensee Action On Previous Inspection Findings 2.1 (Closed) Inspector Follow-up Item (219/84-06-06):

Licensee to strengthen the controls over temporary changes to procedures.

A review of the Control Room Temporary Change Notice Log Book indicated that it was being maintained and kept up-to-date on a daily basis.

Also, several temporary changes were reviewed to verify that they have been recorded in the respective procedures in which the temporary change had been written against.

Discussions were also held by the inspector with the control room Group Shift Supervisor to provide added assurance that the necessary controls were in place and were being implemented as required.

Based on this review, this item is closed.

2.2 (Closed) Noncompliance (219/81-08-01):

Licensee to install service water flow instrumentation for inservice test purposes.

This item involved several concerns, all of which were previously reviewed and closed out in inspection 219/85-01, with the exception of the installation of the flow meter in System II of the Emergency Service Water system.

The inspector verified through direct observation that an Annubar flow sensor had been instal. led on the Emergency Service

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Water, System II.

Based upon this review, this item is close.

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2.3 (0 pen) Violation (219/83-26-01):

Fire pump surveillance procedure

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failed to incorporate new changes as a result of a Technical

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Specification (TS) amendment.

Through a review of the affected fire i

pump surveillance procedure, discussions with Oyster Creek personnel and a review of responses and other documents pertaining to the violation, the inspector determined that the fire pump surveillance procedure had been updated to reflect the latest T.S, requirements.

However, during review of Licensee Event Report (LER) No.85-008, it was noted that in 1985, the licensee had again failed to incorporate a TS amendment into applicable surveillance procedures. This LER i

stated that the apparent cause of the occurrence was due to a

" breakdown in the administrative controls which are intended to assure that the necessary actions required to implement changes in

T.S. are properly assigned and monitored for completion." One such control mechanism utilized at the site is the Licensing Action Item l

(LAI).

LAI's are issued by Licensing to track the cycle of TS i

amendment incorporation into plant procedures.

However, during this

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inspection, the inspector noted that LAIs had not been issued for a

number of recent TS amendments.

No additional instances were

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identified in which T.S. amendments had not been incorporated into applicable surveillance procedures.

The licensee stated that it was not deemed necessary to generate LAIs for those instances identified j

by the inspector. They also stated that additional mechanisms were i

in place which provided added assurance that necessary actions would

be completed.

(The inspectors were however unaware of any other existing mechanisms in place prior to the exit meeting.) Prior to

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the conclusion of the inspection, LAIs were generated and issued against these T.S. amendments.

Subsequent to the inspection through a telephone conversation with i

the licensee on June 18 1987, the inspector was informed by a licensee representative of other actions that had been taken or are q

planned in regard to the above concern.

These actions include the

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following.

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The licensee will review all TS amendments issued since January

1985 to provide assurance that appropriate action (ie.,

procedure change) was completed.

LAIs will be generated against all T.S. amendments even if appropriate action has

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already taken place.

For further TS changes, an LAI will be issued in regard to the

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TS change request and another LAI will be issued upon receipt i

of the respective TS amendment.

The inspector concludes from the above review and subsequent telephone call, that the licensee has adequately addressed NRC concerns in this area.

However, until such time that the licensee demonstrates that the above mentioned actions are being properly accomplished, this item remains open.

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3.0 Surveillance and In-Service Testing (IST) Activities 3.1 References / Requirements

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10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants.

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Regulatory Guide 1.33, Quality Assurance Program Requirements.

American National Standard (ANSI) N18.7-1976, Administrative l

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Controls for Nuclear Power Plants.

Technical Specifications -- 3.2 Surveillance Testing, Procedures and Records This portion of the inspection included a review of the surveillance-program, procedures, and applicable records.

3.2.1 Surveillance Program

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The inspector reviewed the program to determine that a master l

schedule for surveillance testing / calibration has been established and included the following.

The frequency for each surveillance

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The plant group responsible for performing each

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surveillance The status of each surveillance test

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In addition, the inspector reviewed the formalized methods that have been defined for the review and evaluation of surveillance data, including procedures for reporting and reviewing deficiencies.

3.2.2 Surveillance Procedure Review i

The inspector reviewed a random sampling of surveillance procedures (listed in Attachment 1) for the following

attributes.

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The presence and adequacy of prerequisites The incorporation of acceptance criteria in accordance with

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Technical Specification (TS) requirements

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The provisions for restorati.on of equipment and systems L

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The adequacy of procedure content

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The incorporation of Technical Specification amendments, f

where applicable 3.2.3 Review of Completed Surveillance Activities I

A sample of surveillance records corresponding to the procedures reviewed in section 3.2.2 of this report were reviewed against the following applicable requirements.

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Surveillance were conducted in conformance with TS

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requirements

Completed surveillance were reviewed as required by

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administrative procedures

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Surveillance were performed within the time. frequencies specified in the Technical Specifications

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Appropriate action was taken for any item failing the acceptance criteria d

Attachment 1 contains a complete list of surveillance records that were reviewed.

3.2.4 Findings By reviewing the applicable administrative procedures, the surveillance procedures themselves, and a sample of completed surveillance records, the inspector determined that the surveillance reviewed during the inspection conformed to regulatcry and administrative requirements.

Procedures were noted to specify acceptance criteria as designated in the TS.

In almost all cases, procedures were written in such a way as to distinguish between TS acceptance criteria requirements and other less critical criteria.

This clarification in the acceptance criteria section of surveillance procedures aids in the determination of whether a component or system is to be declared inoperable.

The master schedule for surveillance was found to indicate all the information specified in section 3.2.1 of this report.

Tracking of TS surveillance was being performed by the Plant Material Group.

The inspector did not identify any surveillance that had not been performed, or had exceeded their time limit interval.

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The sampling of surveillance procedures reviewed contained the latest TS amendments and had restoration steps incorporated into each individual procedure.

Deviation Reports had been initiated for surveillance which had failed the acceptance criteria.

Surveillance records identified these deviations, and displayed proper documentation in the j

records reviewed.

Further review indicated that appropriate corrective actions had been taken in regard to these deviations.

The inspector also reviewed the " Cross Reference of Surveillance Procedures and Technical Specification," which is attached to Administrative Procedure 116, Surveillance Test Program, Rev.

20.

The cross-reference was observed to be current through TS Amendment No. 97.

Because the current TS had Amendment No. 116, i

the inspector questioned the licensee concerning the length of

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time involved since TS Amendment No. 9'l became effective q

(approximately 1 year earlier).

The licensee stated that a more (

current cross reference was in the review process.

The inspector

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verified that the prospective revision did include all TS

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amendments current at the time the review process for this document revision commenced.

The inspector determined that the document was being updated periodically, and had no further

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questions at this time.

i No viclations or deviations were identified.

j 3.3 Inservice Testing of Pumps and Valves 3.3.1 Scope of Review The inspector reviewed various administrative and surveillance test procedures to ascertain compliance with 10 CFR 50.55a(g)

which requires Inservice Testing (IST) of pumps and valves in accordance with Section XI of the ASME Boiler and Pressure Vessel Code. A major portion of this review was an evaluation of the licensee's IST program with respect to procedures, conduct of tests, and analysis of results.

3.3.2 Review / Implementation The inspector reviewed applicable administrative procedures and various IST surveillance (listed in Attachment 1) for technical

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adequacy and to ascertain compliance with the requirements of Technical Specifications,Section XI of the ASME Boiler and Pressure Vessel Code, and 10 CFR 50.55a(g).

A random sampling of completed IST surveillance verified that

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the following attributes were being accomplished with respect to inservice testing.

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Applicable surveillance test procedures were approved and l

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up-to-date i

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Any applicable temporary changes were noted within the procedures

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Calibrated test equipment utilized during the performance

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of the surveillance was listed J

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Acceptance criteria were listed within the procedure

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Appropriate steps were taken, i.e., increased testing frequency, corrective maintenance, retests, were taken if acceptance criteria were not met Appropriate reviews were performed following completion of

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the test Further reviews of IST program implementation, including evaluation of test results, trending, recording, etc. is

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detailed in paragraph 5.0 of this report.

3.3.3 Findings No violations were identified; however, the inspector did i

express a concern over the timeliness to which completed

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surveillance are filed in the document control center.

Instances were noted where as long as 9 months had expired since i

the completion of the test and it had not yet been stored in the

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respective record file.

The licensee acknowledged the

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inspectors' concern and stated that this area would be reviewed and appropriate action would be taken.

The inspector had no further questions.

l 4.0 Independent Calculations 4.1 Verification of Reactor Building to Suppression Chamber Vacuum Breaker Operability Technical Specification (TS) 3.5.A.4 requires that the Reactor Building to Suppression Chamber Vacuum Breakers actuate with less than a 0.5 psi differential pressure across the valve seat.

These valves are 20-inch, self actuated type, and are installed to prevent a vacuum from being created in the suppression pool.

During a plant tour, the inspector noticed that the valves in question did not have weights installed on the weight levers.

These weights can be utilized to allow a che.ck valve to open with less force applied to the valve than without the weights installed.

The

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l inspector subsequently reviewed the system design to verify that the valves would open with less than.5 psi across their seats. After

.J obtaining applicable drawings and other valve specification, such as j

weight of the valve seat, weight _of the weight. arms and certain i

distances, the inspector calculated whether the valves should actuate j

when a.5 psi differential pressure was-applied to.their seats. The

. inspector determined that'the valves should open as required assuming that excessive friction was not present in the valves hinges.

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inspector then checked surveillance records for the. valves in' order to compare actu'al forces to open the valves against the calculated-j valve.

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The actual force values, as recorded on' completed surve'111ance records were determined to be in an' expected range, based on the

inspector's calculations.

The inspector then mathematically verified j

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that the acceptance criteria for the applicable surveillance

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(procedure 604.4.003, Rev. 3) was'in conformance to TS! requirements.

The results'of the inspector's calculations agreed with the

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surveil. lance acceptance criteria which were derived from TS

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requirements and incorporated into the surveillance procedure.

Actual force values'to open the valves were determined to represent a j

small fraction of the maximum force allowable (maximum force q

represents the maximum force based on the TS differential. pressure

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requirement). The inspector concluded that TS requirements a're.

accurately incorporated into the surveillance and that the acceptance

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criteria have been met in previous performances of the surveillance.

1 No violations or deviations were identified.

5.0 Engineering Involvement i

As noted previously, engineering is primarily responsible for controlling the conduct of IST activities.

They also perform reviews of all completed IST tests and subsequently track, document and trend components

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performance.

The inspector discussed with both the IST Pump and IST Valve Coordinators, various aspects of the IST program implementation. Also j

reviewed were Pump Operability Test' Summary Sheets, Cold Shutdown and Refueling Test Lists, Valve Test Summary Sheets, Valve Trend Analysis Sheets, etc. The inspector found these records being maintained and i

up-to-date.

6.0 Exit Interview The inspectors met with licensee representatives on May 15, 1987, to

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summarize the scope and findings of the inspection.

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A subsequent telephone disucssion concerning licensee' action, in regard to previous inspection finding 219/83-26-01, was conducted between the inspector and Mr. J. Rogers on June 18, 198.7.

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At no time during the inspection was written material provided to the l

licensee by the inspectors. The licensee did not indicate that any

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proprietary information was contained within the scope of this inspection.

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Attachment 1 Surveillance Procedures Reviewed Reactor Building to Suppression Chamber Self Activating Vacuum Breaker

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Surveillance Test and IST, Procedure No. 604.4.003, Rev. 3.

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Core Spray Header Differential Pressure Test and Calibration, Procedure

No. 610.3.004, Rev. 12.

i Excess Flow Check Valves Functional Test, Procedure No. 604.3.008.

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617.4.003, Rev. 8.

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ARPM Surveillance Test and Calibration, Procedure No. 620.3.003, Rev. 15.

  • ADS Actuation Circuit Test and Calibration, Procedure No. 602.3.005, Rev.
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High Flow in the Main Steam Line Test and Calibration, Procedure No.

  • 619.3.005, Rev. 16.

j Main Station Weekly Battery Surveillance, Procedure No. 634.2.002, Rev.

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Diesel Generator Load Test, Procedure No. 636.4.003, Rev. 27.

  • Diesel Generator Inspection, Procedure No. 636.1.010, Rev. 2.
  • Diesel Generator Automatic Actuation Test, Procedure No. 636.2.001,

Rev. 17.

Shutdown Cooling Valve Operability and IST Valve Test, Procedure No.

  • 613.4.002, Rev. 3, 4.

Emergency Service Water Valve Operability Test Procedure No. 608.4.001,

Rev. 2.

Scram Discharge Volume Vent and Drain Valve Functional Test Procedure No.

  • 619.4.022, Rev. 1.

Reactor Building Closed Cooling Water System Valve Test, Procedure No.

  • 642.4.002, Rev. 5.

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s Attachment 1

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Other Documents Reviewed Administrative Procedure 112.1, Technical Specification Supporting

  • Installed Instrumentation, Rev. 24.

i Administrative Procedure 116, Surveillance Test Program, Rev. 26.

  • i Administrative Procedure 104, Control of Nonconformances and Corrective

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Action Rev. 10.

i Licensing Procedure 006, Plant Technica'l Specification / Operating License

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Change Control, Rev. O.

Licensing Procedure 002, Regulatory Correspondence Control, Rev. 1.

  • Deficiency Reports:

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87-017 87-146

)87-045 87-168

87-091 87-169 87-092 87-210 Oyster Creek Station Tech Spec Log Sheet, Procedure 106, Attachment 7.

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Inservice Testing Program Submittal, Rev. 5, 3/12/87.

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