ML20011F664

Responds to NRC 900122 Notice of Violation & Forwards Payment of Civil Penalty in Amount of $25,000.Corrective Actions:Change Made to Sys Component Lineup Sheets in 125- Volt Dc Operating Procedure to Include Selector Switches

ML20011F664
Person / Time
Site:	Oyster Creek
Issue date:	02/20/1990
From:	Fitzpatrick E GENERAL PUBLIC UTILITIES CORP.
To:	Lieberman J NRC OFFICE OF ENFORCEMENT (OE)
References
NUDOCS 9003070100
Download: ML20011F664 (4)

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I GPU Nuc6est Corporation l N@ f Post Othee Box 388 Route 9 South Forked R ver,New Jersey 087310388 j

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609 971-4000 l Writer's D# rect Dial Number:  ;

February 20, 1990 1

Mr. James Lieberman, Director l

Office of Enforcement l U. S. Nuclear Regulatory Commission Washington, DC 20555 -i i

Dear Mr. Liebermant -

Subjects Oyster Creek Nuclear Generating Station l l

Docket No. 50-219 Reply to a Notice of Violation - Inspection Report No. 50-219/89-23 and Proposed Imposition  ;

of Civil Penalty I,

In accordance with 10 CFR 2.201, enclosed is GPU Nuclear's reply to the  ;

Notice of Violation and Proposed Imposition of Civil Penalty served with NRC letter dated January 22, 1990. Also enclosed is a check in the amount of l

$25,000.00 which constitutes payment of the imposed civil penalty.

If there are any questions regarding this matter, please contact Mr. Michael ,

Heller, Licensing Engineer, at (609)971-4680.

Very truly yours, E. E. Fitatp ick Vice President and Director

[ Oyster Creek l EEF/MGH/dmd IR89-23 Enclosures cc: Mr. William T. Russell, Administrator Document Control Desk Region I US NRC US NRC Washington, DC 20555 f 475 Allendale Road King of Prussia, PA 19406 n M.'Alex W. Dromerick, Project Manager Resident Inspectors g I

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US NRC l Washington, DC 20555 Oyster Creek @

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GPU Nuclear Corporation is a subsidiary of the General Pubhc Utilities Corporation +

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i f . 1 ENCLOSURE 1 REPLY TO A NOTICE OF VIOLATION 1 I. VIOLATION ASSESSED A CIVIL PENALTY i 10 CFR 50, Appendix B, criterion XVI requires, in part, that measures shall be established to assure that conditions adverse to quality be promptly identified and corrected. In the case of significant conditions j adverse to quality, the measures shall assure that the cause of ths  ;

condition is determined and corrective action taken to preclude <

repetition, oyster Creek Station Procedure 104 (Control of Nonconformances), i established to meet the requirements of 10 CFR 50, Appendix B, criterion I XVI, requires in Paragraph 5.1, that personnel who become aware of a condition adverse to quality shall document it using appropriate means or shall report it to their supervisor. Paragraph 5.6 requires, in part, that Deviation Reports should be prepared for significant conditions ,

adverse to quality. Appendix I of this procedure defines a significant  ;

control adverse to quality to include operation of a safety-related  ;

system contrary to that as described in the Final Safety Analysis Report 5 (FSAR). Section 8.3.2 of the FSAR states that a safety-related DC l control power source is required for the unit substation (USS) IB2 breaker control power. [

Contrary to the above, between February 25, 1989 and September 16, 1989, licensee personnel were aware of a significant condition adverse to '

quality,.as identified en six occasions during that time. However, the condition was not documented on a deviation report and was not corrected until September 16, 1989. The specific condition adverse to quality involved the Unit substation USS 1B2 breaker control power being aligned  ;

to the "A" DC distribution system, which was not a safety-related DC control power source, in that it was not seismically qualified.

II. VIOLATION NOT ASSESSED A CIVIL PENALTY ,

10 CFR, Part 50, Appendix B, Criterion V, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of the type appropriate to circumstances and shall be accomplished in accordance with these instructions, procedures or drawings.

Oyster Creek Operational Quality Assurance Plan, established in accordance with 10 CFR Part 50, Appendix B, Criterion II, requires, in Section 6.10.1.2 (Control of Station Activities), that procedures shall be provided for control of equipment, as necessary, to maintain personnel

• and reactor safety, to avoid unauthorized operation of equipment, and to l

assure that operational equipment is in a ready status.

Contrary to the above, prior to September 16, 1989, certain procedures for the control of equipment affecting quality were not adequate to assure that operational equipment was in a ready status in that Station Procedure 340.1, "125 VDC Distribution Systema "A" and "B", and Station Procedure 338, "460 Volt Electrical System," did not specify the required position for the Unit substation (USS) 1B2 control power selector switch.

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RESPONSE GPUN concurs with both violations cited above.  ;

l The root cause of the failure to promptly correct the condition is attributed  ;

to the failure of informed individuals to utiliae proper corrective action )

programs. A contributing cause is that the Technical specifications i associated with the B battery alignment are ambiguous.  ;

1 The root cause of the switch mispositioning is attributed to procedural  !

I inadequacy.. The primary inadequacy was that the position of the manual transfer switch was not included on the applicable line-up check list in Procedure 340.1, "125 Volt DC Distribution System A & B". A secondary inadequacy was that the as-left positions were not required to be recorded on the log sheets in Procedure 108, " Equipment Control" when a temporary lif t i was not rehung. I l

Full compliance was achieved on September 19, 1989 when the manual transfer j switch was repositioned to supply control power for USS-1B2 from the I safety-related B battery.

GPUN believes the condition had minimal safety significance because safety l systems would have been able to' perform their functions. Nevertheless, i comprehensive corrective actions have been taken to preclude recurrence as I follows:

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1. When it was verified that the switch was selected to the wrong power source, corrective action was taken to position the switch to the safety ,

related DC power source. '

2. Procedures and drawings were reviewed to identify similar switches, and a visual inspection of these switches was performed to verify correct positions. '

3. A change was made to the system component lineup sheets in the 125V DC operating procedure to include the control power selector switches for all 4160V and 480V AC switchgear.

4. Operations management has reviewed the 125V distribution system with all ,

Operations Department personnel and reviewed the restrictions associated with the usage of the A battery. The Manager of Plant Operations issued-a memorandum addressing this incident and the safety significance associated with placing USS-1B2 on the A battery.

5. An independent review group was established to review the circumstances ,

of the event and to identify required actions prior to plant startup.

Corrective actions were discussed with NRC regional management in a conference call on September 16, 1989 prior to plant startup.

6. An independent root cause analysis team was established and chartered for the purpose of finding the root cause(s) of the misaligned switch. A final report with conclusions and recommendations was issued on October 13, 1989. All recommendations are captured by the corrective actions described in this response.

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7. An internal security department investigation was initiated on September 18, 1989. This effort was superceded by an external independent investigation on September 21, 1989. The purpose of this combined effort was to determine who knew of the switch position, when they knew of it,

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and if such information was properly addressed. A final report with I conclusions was issued on November 14, 1989. GPUN has taken appropriate J action to address the conclusions. '

8. The Oyster Creek Director issued a memorandum on September 22, 1989 i emphasizing the requirement to document deficient conditions. The l President CPUN issued similar company-wide guidance.

9. Procedure 108, " Equipment Control" was rrrised to implement a computerited tagging system (TRIS - Tagging Retrieval Information System). This new system generates component position requirements whenever a worksheet for tagout removal is generated.

10. Procedure 108, " Equipment Control" was revised to ensure tagged components are listed in the applicable system line-up sheet.

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11. A program is in place to review component line-ups, operating procedures, and drawings to ensure that all components are listed on line-up sheets.

This data is being captured on a computerited data base and will be used to generate accurate, thorough and standard system line-up sheets.

12. A surveillance procedure is being developed to periodically check the position of critical electrical components.

13. Training programs are being enhanced to introduce trainees to the identification and utilization of corrective action programs.

14. Procedure 124, " Plant Modification Control" was revised to require the Startup & Test Department to provide the operations Department with a  ;

list of all components which were manipulated during their testing ,

evolutions and any new components which were installed as a result of a modification. This list must then be compared to the system line-up check list to ensure all components are listed and positions specified.  ;

15. Training materials are being revised to incorporate this incident as a lessons learned item.

16. The manual transfer switch for USS-1B2 control power will be modified to ,

preclude inadvertent mispositioning of the switch to the A battery.

17. Technical Specification Change Request No.182 was submitted on December 4, 1989 to clarify Technical Specification requirements associated with the station batteries.

18. Labeling for the manual transfer switch was improved to designate the normal position and to indicate which power source is safety-related and which is not.