ML19339C259

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Responds to NRC Re Violation Noted in IE Insp Rept 50-219/80-23.Violation Was Due to Personnel Error,Not Lack of Adequate Mechanism.Present Sys Considered Adequate. No Changes Planned
ML19339C259
Person / Time
Site: Oyster Creek
Issue date: 09/15/1980
From: Finfrock I
JERSEY CENTRAL POWER & LIGHT CO.
To: Galen Smith
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19339C258 List:
References
NUDOCS 8011170937
Download: ML19339C259 (3)


Text

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Jersey Central Power & Ught Company Madison Avenue at Punen Bowl Road 2

Mcmstown. New Jersey 07960 (201)455-8200 9

September 15, 1980 Mr. George H. Smith, Chief Fuel Facility and Materials Safety Branch Office of Inspection and Enforcement United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Pennsylvania 19406

Dear Mr. Smith:

SUBJECT:

Oyster Creek Nuclear Generating Station Docket No. 50-219 IE Inspection 80-23 This is in reply to your letter of August 20, 1980 regarding the inspection conducted by Mr. K. Plumlee from May 28, 1980 to July 11, 1980 at the Oyster Creek Nuclear Generating Station. In Appendix A of your letter there is noted an activity which apparently was not conducted in full compliance with the conditions of the Oyster Creek NRC Facility License. The itec, an infraction, and our response to it are given below.

Infraction Technical Specification 6.8.1 states in part, '*Jritten procedures shall be established, imple=ented and maintained that meet or exceed the require =ents of Sections 5.1 and 5.3 of American National S tandard N18.7-1972...."

American National S tandard N18.7-1972, Section 5.1.4, "Special Orders",

states in part, "A mechanism shall be provided for issuing management instruc-tions that have short term applicability and require dissemination. Such instructions, sometimes referred to as special orders, should encompass special operations or other similar matters...."

Contrary to the above, there is no adequate mechanism provided for the issuance of =anagement instructions of short term applicability that require dissemination.

This lack of management and procedural controls resulted in about a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> delay on June 5,1980 in establishing a fire watch patrol, required by Technical Specification 3.12.E.2, to be initiated within one hour when certain fire protection barriers were found to be non-functional, af ter verbal instructions to initiate the fire watch were given by the station super-intendent.

8011170 N Jersey Central Power & Lght Ccmcary :s a Memcer et the General Puthc UtMties System

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II Inspection 80-23 Page 2 September 15; 1980

Response

The situation leading to this Notice of Violation (apparent item of non-l compliance.50-219/80-23-01) is correct as s tated. A verbal directive from the Station Manager to the Group Shif t Supervisor was not implemented for some 16

- hours. This delay caused a violation of the Technical Specifications.

i The violation was reported by telcon to the NRC Resident Inspector upon discovery and by Licensee Event Report 50-219/80-20/1T. The delay in implemen-

. cation was due to personnel error. Simply stated, the attention of the Group Shif t Supervisor was diverted by other operations in progress and he failed to implement the directive. The omission was detected, corrected, and reported by site management. As stated in the Licensee Event Report, "Those personnel involved with the failure to carry out the required fire watch were instructed as to the importance of the fire watch and the necessity to provide the informa-tion to succeeding shif ts."

The basis for the Notice of Violation has been reviewed.and it is concisced the cause of this occurrence is the failure of personnel to follow the established mechanism, not a lack of adequate mechanism.

This conclusion is based on the existing mechanism, in use at Oyster Creek, to issue and disseminate " management instructions that have short term applicability" namely; Shif t Turnover, Operation Memos by Supervisor-Station Operaticus and Standing Orders. In this particular incident, the Shif t Turnover procedure was applicable.

The primary method is by verbal instructions issued by supervisory personnel and disseminated by Shif t Turnover. Administrative procedure 106, " Conduct of Operations", provides for authority of Operations supervision to direct plant activities, responsibility of Operatioca Department personnel to follow instruc-tions issued by competent authority and to operate the plant in accordance with license requirements, and responsibility of Operations personnel to conduct an effective turnover of information to their relief.

The primary method is backed up by aritten memos issued by the Supervisor-j Station Operations. Our administrative procedure 106, " Conduct of Operations",

l states in part, " Supervisor Station Operation Orders and Memos are instructions provided to g1ve guidance concerning Plant Operations covering short periods of time."

These menos are customarily issued with a routing list attached, to be j

initialled as each Group Shif t Supervisor or Group Operations Supervisor reviews the memo, and to be returned when complete.

Standing Orders are established and controlled by administrative procedure j

115, " Standing Order control".. Operations personnel are directed to follow standing orders in administrative procedure 106, " Conduct of Operations".

As a result of this occurrence, the mechanisms in use at Oyster Creek have 4

been reviewed to assess their adequacy to fulfill the requirements of the refer-enced sections of ANSI Standard N18.7-1972.

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IE Inspection 80-23 Page 2 September 15, 1980 Our present syste:a is considered adequate and no changes are planned.

Since the present system is in use and considered adequate, full compliance is being maintained.

Very truly yours, M'

Ivan R. Finir Vice Preside eration ck 1

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