IR 05000219/1987023

Insp Rept 50-219/87-23 on 870629-0702.Violation Noted.Major Areas Inspected:Qa Records Program & Licensee Action to Resolve Previously Identified Concerns

ML20236P623
Person / Time
Site:	Oyster Creek
Issue date:	08/06/1987
From:	Dev M, Eapen P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20236P604	List: IR 05000219/1987023 ML20236P602 ML20236P620
References
50-219-87-23, NUDOCS 8708120445
Download: ML20236P623 (10)

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U.S. NUCLEAR REGULATORY COMMISSION i REGION I ,

Report N /87-23

Docket N License N DPR-16 Licensee: GPU Nuclear Corporation Oyster Creek Nuclear Generating Station 1 P.O. Box 388  !

Torked River, NJ 08731 )

I Facility Name: Oyster Creek Nuclear Generating Station  !

I Inspection At: Forked River, New Jersey '

Inspection Con ted: June 29-July 2, 1987 Inspector: /

M. Dev, PE, Reactor Engineer, DRS S S[

' bath Approved by: (A Dr. P. K. Eapen, Chief, Quality Assurance trdN7

~dat'e Section, Operation Branch, DRS Inspection Summary: Routine Unannounced inspection on June 29-July 2,1987

{ReportNo. 50-219/87-23).

Areas Inspected: QA Records Program, and the licensee's action to resolve  !

previously identified NRC concern j

Results: One violation was identified for the licensee's failure to implement biennial review of the station procedure (

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DETAILS Persons e Contacted 1.1 General Public Utilities-Nuclear Corporation (GPUN)

• R. Blouch, Manager, Technical Support

• G. Busch, Licensing Engineer

. . . * G. Faulkner, Manager, QA Welding Engineering

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• P. Fiedler, Vice President and Director, OCNGS

• S. Fuller, Operation QA Manager R. Larzo, Engineer, Spare Parts Evaluation A. Lewis, Supervisor, Document Control Center

• D. MacFarlane, Site Audits Manager D. Quilty, Supervisor, Nuclear Warehouse Operations J.' Regers, Licensing Engineer

• A. Rone, Plant Engineerin,q Director F. Sellitto, Administrator / Supervisor, Micor/ Repro / Vault

• P. Thompson, QA Auditor

• R. Weltman, Mechanical Material Manager 1.2 United States Nuclear Regulatory Commission (USNRC)

W. Bateman, Senior Resident Inspector

• Denotes those present at the exit meeting held July 2, 198 The inspector also contacted othu technical and administrative personnel during this inspectio l 2.0 Licensee's Actions on Previously Identified NRC Concerns (Closed) Unresolved Item (50-219/79-18-28): .This item pertains to the licensee's inadequate shelf life control of spare parts, components and replacement Subsequently, the licensee revised the Oyster Creek Nuclear Generating Station Procedure No. 105, Control of Maintenance, and incorporated a )

paragraph which positively stated, "Use no materials, the shelf-life of l which has expired." Accordingly, materials having less than'30-days )

-remaining shelf-life are not issued for use, and the shelf-life identi- )

fied on the PQA Tag constitutes the final permissible installation dat ]

Currently, all safety-related spare parts and replacements are installed per the Station Maintenance Work Requests. The QA surveillance and audit ]

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activities have verified the adequacy and effectiveness of the licensee's action for shelf-life contro In addition, discussion with the Oyster Creek Warehouse Supervisor, and a random check of shelf-life for selected I components indicated that the licensee's equipment shelf-life program is l

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adequate. This program also provides controls for the shelf-life related engineering disposition of spare parts and components 90-days prior to tneir actual expir Based on the above, the inspector determined that the licensee's action for the equipment shelf-life control is adequate. This item is closed.

i (Closed) Inspector Follow-up Item (50-219/84-06-01): Licensed Operator Requalification Examination Program.

l During the 1983 licensed operator requalification examination, certain individuals who could not successfully complete the accelerated requali-i fication program wer'e required to take the second requalification exami-

! nation. Five of these operators could not pass the second examinatio The licensee chartered an oral board to determine if they should be removed from the licensed duties. These individuals when given subsequent written and oral examination, successfully passed and returned to licensed l duties by the end of April 198 Currently, the licensee is implementing INP0's Licensed Operators Accreditation Program which has completely revised and updated the licensee's previous licensed operator training progra Based on the above, the licensee's action is considered adequate. Thi s item is close (Closed) Unresolved Item (50-219/86-03-01): Non-Licensed Staff Trainin The non-licensed operators at the OCNGS were not trained to verify the calibration status of the instruments during data collection. Some data were recorded from the equipment whose calibration was overdue. To address this deficiency in on-the-job training of the non-licensed operator, the licensee management instructed the first line supervisors to emphasize the instrument calibration requirements in operator-tour trainin In addition, the Plant Operation Director issued two memoranda which recognized the lack of consistency in the operator-tour or turnover check activities and directed the cognizant supervisors to review the requirements and guidelines provided in Procedure-106 regarding operators'

checklist, turnover and tou Accordingly, the training department included these requirements in the Non-licensed Operator's Training Program. The licensee management also conducted review of the tour sheets and evaluated equipment specification in order to verify and control "out of Specification" data collection and recordin Based on the above and verification of the status of the equipment calibration of selected surveillance test activities, the inspector determined that the licensee's action to emphasize the monitoring of the equipment calibration status by the non-licensed operators is consisten This item is closed.

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(0 pen) Violation (50-219/86-11-02): Failure to implement Fire Protection related corrective action in a timely manne The licensee's QA audit S-0C-84-19-06, dated October 12, 1984 performed to satisfy T.S.6.5.3.2a, identified a through wall crack in the west wall of the south stairwell located in the turbine buildin In the Fire Hazard Analysis Report the wall was identified as a 2-hour rated fire barrier wall. The crack, thus, constituted a violation of NFPA-101, state law and a deviation of the licensee's commitment to maintain thi< wall as i a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> fire barrier. The licensee initiated an engineering work order i for the repair of the wall crac Subsequently, the licensee's Main-tenance, Construction and Facility Department completed the repair work in accordance with specification OC-IS-315302-041 per Maintenance Work Request No. 33080. The job was completed on July 14, 1986, and subse-quently, this audit finding was closed. The inspector verified that the l wall was repaired as stated in Maintenance Work Request No. 3308 The NRC inspection (50-219/86-11-02) identified the licensee's protracted corrective action as a violation of 10 CFR 50, Appendix B criteria XV In letter dated June 26, 1986, the licensee responded that the condition of the crack in the wall did not represent a plant safety or personnel hazard, and as such the repair was assigned a lower priority based on normal plant resources and work load. The licensee also did not concur in this violation. The licensee's response is currently being reviewed by the NRC Region I staf Based on the review of the turbine building stairwell fire prerection repair work, the licensee action is considered complete. This item remains open pending disposition of the violation by the NR .0 Records Management Program TSe basic requirements and guidelines for collection, storage and maintenance of Quality Assurance Records are described in:

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10 CFR 50, Appendix B, Criteria XVII

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Technical Specifications, Paragraphs 6.8 and 6.10

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Regulatory Guides 1.28, 1.33 and 1.88

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ANSI /ASME NQA-1-1979/1981

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Oyster Creek Operational Quality Assurance Plan 3.1 Program Review A review of the Oyster Creek Nuclear Generating Station Record Management System was conducted to verify that the licensee has established and implemented:

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Requirements and provisions to maintain station QA records, and

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Responsibilities and controls for transfer, storage, maintenance, retention and disposal of record . _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___

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The licensee's procedures governing the Record Management program requirements are listed in Attachment- .2 Details of Inspection The inspector reviewed the records pertaining to the licensee's response to the previously NRC identified concerns (See paragraph 2.0). The scope of the review was extended to verify the licensee's compliance to the regulatory requirements related to the licensee's QA Record Management Program for: Procedure Review and Control Audits Procurement Records Operating Records Surveillance Test Results Personnel Training Procedure Review and Control The OCNGS Procedure - 107, Procedure Control establishes the requirements and responsibility for preparation, review, approval and revision control of the station procedure Accordingly, the Safety Review Manager delegates the responsibility for preparation of new and revised procedures and for periodic review of the station procedure to the cognizant department heads. The Director, OCNGS or his designee is responsible for the approval of the station procedure The inspector reviewed the requirements for the periodic review of these station procedures. In this context l it was noticed that the Safety Review Manager had informed the l cognizant department heads on June 5, 1987, of the biennial review of the station procedures which was overdue since December 198 The inspector identified that 16 of these pro-cedures belonged to Operation Engineering, 5 to Mechanical Engineering, 3 to Fire Protection, and 21 to the Maintenance, Construction and Facility department. The licensee's represen-tative stated that if the procedures are not reviewed within the assigned periodic review cycle, they are considered obsolet However, there was no evidence to that effec The cognizant groups failed to complete the biennial procedures revie Failure to complete the biennial review of the station proce-dures is a violation of 10 CFR 50, Appendix B, Criterion V, OCNGS Technical Specification, paragraph 6.8.2 and OCNGS procedure-107, paragraph 3.3.4 (50-219/87-23-01). Audits The inspector reviewed the licensee QA audits listed in Attachment- The Audit S-0C-86-04 verified the adequacy of the licensee's Information Management Program instituted at the l

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0CNGS. The audit covered the licensee's Record Management System including control of drawings, procedures, records, and the technical manuals and vendor manuals progra The audit verified that the organizational duties and responsibilities for the program were in compliance with the licensee's Operation Quality Assurance Plan. The Site and Corporate Information Management Procedures, established to control station documents and records, were found to be effectively implemented and they met the requirements of the OCNGS Technical Specifications and the Operation QA Pla The inspector discussed the vendor manual update program with the technical librarian. Vendor manuals were selected from the computerized listing to verify their availability and update statu Though the computerized listing was not up to date, the librarian traced the status of these manuals through the com-puter termina It is evident that the licensee is in the process of efficiently organizing and updating the vendor manuals and other vendor informatio The audit also reviewed the training records and verified that the Document Control Center personnel were adequately trained and qualified in accordance with the requirements delineated in the procedure 7133-ADM-2600.0 The audit also verified the effectiveness of the licensee's procedures and document control program through the review of controlled distribution document log, and transmittal slip The audit provided two recommendations to help resolve the slow turnaround which are currently reviewed by the licensee's managemen Subsequent audit S-0C-86-08 verified the licensee's compliance to the regulatory requirements including organization, personnel training, procurement and record management. Another audit S-0C-86-16 was devoted to review the adequacy of the licensee's action to effectively implement the corrective action delineated in LERs, QDRs and NRC Notice of Violations and deviation Audit S-0C-86-17 specifically reviewed the licensee's training program for licensed operators, non-licensed operators, STA and maintenance personne It also updated the status of INPO Accreditation of the Licensed and the non-licensed operators training program. Audit S-0C-87-02 reviewed the licensee's Material Management activities. This audit verified the imple-mentation of the licensee's Operation QA Plan and concluded that the control of procurement, receipt, inspection, storage and handling at the warehouse was adequat No violations were identified within the scope of this inspectio _-_ _ _ __ _ _ - ______

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lq Procurement Records i U l De inspector randomly selected four of the recently completed l procurement records and verified that quality requirements )

including 10 CFR 21, equipment environmental qualification, and ]

shelf-life were properly identified and verified during receipt '

l inspection. 'The inspector also discussed with the warehouse supervisor.the procurement, storage and handling, and receipt inspection process, and verified the disposition of. items through physical inspection of four items (see Attachment-1).

D. Operating Records The inspector reviewed the records for the recently completed operating records for Jumper Installation, and Station Operating Logs and Charts. The records for the following items were prepared in accordance with the licensee's procedure-108 i and were properly dispositioned, documented and maintaine Station Operating Log No. 87-32, Recirc Tempt DigitalLIndicator-87-37, Control Rod Drive-87-48, N 2Compressor 87-65, US2T Transformer E. Surveillance Records The inspector reviewed the following surveillance test records maintained in the Decument Control Center and found them properly dispositioned and maintaine . Drywell to Torus DP Indicator Calibration, Procedure 604.3.012, Dated October 12, 1985 and April 9, 198 . Drywell H2 /02 Analyzer Surveillance Test, Procedure 604.3.020, Dated April 9, 198 F. Personnel Training Records The inspector reviewed the maintenance of the personnel training records of selected licensed and non-licensed operator Also, a discussion was held with the training ,

department cognizant instructors and verified that computerized 1 training data reporting and individual training records were adequately organized and maintained in the fire-rated cabinets, and were administratively controlle The inspector reviewed the training records of the personnel performing record management activities and found them adequately trained and indoctrinated in accordance with the Station Procedure 7133-ADM-2600.01, Oyster Creek Document Center-Training of Personne _ _ _ _ _ -

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1 3.3 Document Control Center Walkdown The. inspector walked down the licensee's Document Control Center and Vault area and discussed the licensee's Records Management System with the cognizant personnel . The OCNGs has dual document storage facilities at the-site. All plant records and documents are trans-mitted_to the Document Control Center located in the engineering /

technical building for recordkeeping. The Document Control-Center upon verification'and check for proper documentation forwards them to the Microfilm / Reproduction / Vault department for microfilming and retention of the duplicate document on a long term basis. The original documents are returned to the document control center. All radiographs, light sensitive, and safeguard information, are kept.in the vault. The Document Control Center and Vault are (ccess control-led and'the access list is updated periodically as required. The vault is humidity controlled and uses halogen for fire protectio The cabinets for temporary storage are fire rated and administra-tively controlle .4_ Conclusions

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The licensee's record management program is adequately' organized and j effectively functioning. The plant documents and data are easily retrievable. The record management group is adequately staffed with qualified and trained personnel to manage the activitie One violation was identified in the are of the biennial review of the station procedures. This has been discussed in detail in paragraph 3. '

4.0 Management Meetings The pisnt management was informed of the scope and purpose of this inspection at an entrance interview conducted on June 29, 1987. The findings of the inspection were periodically discussed with the licensee's cognizant representatives during the course of this inspectio The exit interview was conducted on July 2,1987 at which time the findings of the inspection were presented. The licensee did not indicate that any proprietary information was contained within the scope of this i inspectio At no time during this inspection was written material provided to the 6 licensee by the inspector.

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1.0 Document Reviewed Oyster Creek Nuclear Generation Station (OCNGS) Procedure No~. 103, StationLDocument-Control, Ren 20, April 19, 198 .0CNGS Procedure No. 107, Procedure Control, Rev. 31, April, 2 398 j l

OCNGS Procedure No. 130, Conduct of Independent Safety Reviews and'

Responsible Technical Reviews by. Plant Review Group, Rev. 3,'May 15, 198 POL-1210.01, Record Management Policy, Rev.-0, April 1,.1983

.1000-POL-1210. 02, GPU-Nuclear Record Retention Policy, Rev. 0-00,: August 29, 198 ADM-1010.01', Oyster Creek Document Control Center Organization'and Responsibility, Rev. 20, April 19, 198 '7133-ADM-1210.01, Record Management System, Rev. 2, August 2, 198 ADM-1211.01, Processing Incoming Document Indexing Slip, Rev. 2, February 14, 198 .7133-ADM-1211.02, Collection, Processing and Filing of Operations Logs, Rev. 2, February 14,'198 ADM-1211.03, File Maintenance and Retrieval, Rev. 2, February 14, 198 ADM-1211.06, Document Control Vault, Rev. O, January 16, 198 ADM-1215.02, Distribution and Control of Approved Vendor Technical l Manuals. Rev. 3, April 9,198 ADM-1602-01, Production of Microfilm, Rev. O, October 20, 198 ADM-2600.01, Oyster Creek Document Control-Training of Personnel, -

Rev.1, February 14, 198 .0 Audits i j

S-0C-86-04, Information Management, April 1 - May 30, 198 '

S-0C-86-08,'GPU-Nuclear Audit of the Oyster Creek Plant Engineering, June 10 - September 24, 198 )

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Attachment 1 2

} S-0C-86-16, Corrective Action, November 20, 1986 - February 5,198 S-0C-86-17, Training, November 24, 1986 - February 24, 198 S-0C-87-02, Material Management, March 4 - April 14, 198 !

3.0 PQA Package (Procurement)

OP-047452, Motor Limitorque-Relianc OP-047535, Weidmuller Terminal Bloc :

OP-047589, RTV-102 Silicon OP-048506, IC Chip, i

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