ML20032E940
| ML20032E940 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 09/21/1981 |
| From: | Phyllis Clark JERSEY CENTRAL POWER & LIGHT CO. |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8111230519 | |
| Download: ML20032E940 (8) | |
Text
.
r' O.YSTER CREEK NUCLEAR GENERATING STATION M
(609)693 0000 P O BOX 258
- FORKE D RIVE H
- NE W JEFEE Y + 06731 September 21, 1981 n'
, i Mr. Eldon J. Brunne r N
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Acting Director Division of Resident and Project Inspection
. ' f.i U.S. Nuclear Regulatory Commission
~~
Region I M. T/J 0 19315 3
631 Park Avenue u.s, mf u,n King of Prussia, PA 19406
'" 3 *J s
Dear Mr. Brunner:
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Subject:
Oyster Creek Nuclear Generating Station Ibcket No. 50-219 IE Inspection Report 50-219/81-14
'lhis letter is in response to your letter of August 21, 1981, regarding the findings of the inspection conducted by Mr. J. Thomas on July 1-3,1981.
Enclosed is our response to the violations.
If there a re any questions reganling the enclosed information or additional information is required, please contact me or Mr. Michael Laggart of my staf f at (609) 693-6932.
Ve ry truly yours,
~
Philip R.gClark Vice President - Nuclear Jersey Central Power & Light Executive Vice President -
GPU Nuclear Sworn to and subscribed to before me this c9 / day of f
1981.
wi L /d L J Notary Public N
M!CHML LN1GMT PRC:MWL:lse NOTARY l'UDLIC Of firW jrpr,ry T
%Cm w nti;..o33,% y, g y
Enclosure 8111230519 810921 PDR ADOCK 05000219 0
Mr. Eldon J. Entnnsr 2
September 21, 1981 cc:
Mr. Ronald Haynes, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Region I 631 Park Evenue King of Prussia, PA 19406 Director Of fice of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555 NRC Resident Inspecto r Oyster Creek Nuclear Generating Station Forked River, NJ 08731
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,e 9
ENCLOSURE The following information provides a response to the violations contained in the U.S. Nuclear Regulatory Commission letter of August 21, 1981.
VIOLATION A:
Technical Specification 3 5.B.1 states in part, " Secondary containment integrity shall be maintained at all times unless all of the following conditions are met..."
Technical Specification 1.14 states in part, "Se:ondary containment integrity means that the reactor building is closed and the following conditions are met..."
c.
All reactor building ventilation system automatic isolation valves are operable or are secured in the closed position."
Contrary to the above, secondary containment integrity was not maintained f rom about 7 :00 p.m., July 14, 1981 until about 10:15 a.m., July 15, 1981, during which time secondary containment integrity was required, in that a reactor building ventilation system automatic isolation valve, V-28-22, was inoperable and not secured in the closed position.
This is a Severity level IV violation.
RESPONSE
We are in agreement with the violation as stated above. The inoperability of Reactor Building Ventilation System automatic isolation valve, V-28-22, was not immediately recognized by Operations Management as constituting a violation of Secondary Contanment Integrity. At the time of the identification of the valve inoperability, a Standby Gas Treatment System (SGTS) test was being performed which resulted in the inoperability of SGTS #1 (Reference R.O. No. 50-219 /81-30/0lT-0).
Efforts were directed to resolving the problem with SGIS #1 and the inoperability of valve V-28-22, which is in series with another isolation valve V-28-21, that was demonstrated operable, was overlooked.
Upon recognition of the Technical Specification applicability of valve V-28-22, immediate steps were taken to concurrently commence a shut down of the plant and secure the valve in the closed position.
The valve was manually closed and the Technical Specifications satisfied. Maintenance perf ormed on the valve resulted in the discovery and repair of a faulty plunger and spring assembly of the solenoid which controls the air operator of the valve.
Mr. Eldon J. Brunne r 2
September 21, 1981 The valve was demonstrated to be operable and returned to service.
This valve is checked for operability each time a Surveillance Test is perf ormed on the Standby Cas Treatment System.
Full compliance was achieved at approximately 3:30 P.M. on July 15, 1981.
The cause of the above failure was equipment related, however, the failure to identify the valve inoperability as a Technical Specification limiting condition for operation and the subsequent period of operation in violation of the Technical Specification was an administrative control b reakdown.
Station Management has initiated efforts to increase the awareness of Shif t Supervisors to the need of adequately assessing Technical Specification applicability on all f ailures.
The concern with Shif t Supervisor's working knowledge of the Technical Specification has been expressed by the Resident Inspector in discussion with Operations Management and is documented in the inspection report as an unresolved item (219/81-14-04). A Deviation Report system identifying component failures and the requirement to evaluate such failure / deviation for accepted performance is in effect and controlled by Administrative Procedure 104.
The Group Shif t Supervisors have been directed to identify concerns or prcLlems with safety equipment on the Deviation Re po rt. This system of utilizing the Deviation Report ( Attachment 1 to this enclosure) allows for the proper determination of an occurrence f rom e Technical Specification and reportability concern.
In addition, plans are being formulated with the Training Department to upgrade our Technical Specification training in order to insure that all shif t supervisors are thoroughly informed in the use and understanding of the Technical Specifications, notification requirements, and Administrative Controls of the Station.
The above efforts are indicative of the efforts we are taking to improve our management controls in the arca of plant operations.
VIOLATION B:
Amendment 54 to Provisional Operating License DPR-16, dated May 1,1981 modified Technical Specifications by incorporating section 4.13. A.
Technical Specification 4.13. A requires that each accident monitoring instrument channel shall be demonstrated operable by performance of a channel check at least once per 31 days.
Contrary to the above, no channel checks of the accident monitoring i
instrument channels were perf ormed f rom May 8,1981 until July 13, 1981, a period of greater than 31 days.
This is a Severity Level IV violation.
RESPONSE
We agree with the violation as stated above.
The corrective action I
taken to attain full compliance was to perform the required surveillance on July 13, 1981.
I l
3 Mr. Eldon J. Brunnar 3
September 21, 1981 The cause of this violation can be attributed-to a lack of proper administrative controls. On May 13, 1981, Amendment No. 54 to the Operating License and Tschnical Specifications was received. During this time our Document Control Center located in Morristown, New Jersey was being physically moved to the Parsippany headquarters.
The procedures governing the controlled distribution of Technical Specification changes were, during this time, unworkable.
Consequently, the distribution of the controlled copies of Amendment No. 54 to bookholders was delayed until June 28, 1981.
In order to prevent future violations in this area, the Licensing Department will, upon receipt of future Amendments, distribute information copies to key personnel whose responsibilities involve Tschnical Specification compliance. Our present document control procedures insure that controlled distribution to copyholders is effected in a timely manner.
In addition, the current NRC practice of making Technical Specification amendments immediately effective is impractical in that it does not allow for mailing time from NRC to us nor for any administrative -
time for implementation.
It is therefore requested that future Technical Specification amendments have an effective date of at least two weeks af ter NRC issuance unless an overriding immediate safety concern is involved.
VIOLATION C:
Technical Specification 3.4.E states in part, "The core spray and containment spray pump compartments doors shall be closed at all times except during passage...".
Contrary to the above, on July 31, 1981, at about 5:30 p.m., the southeast containment spray pump compartment door was found open and not being used for passage. This is a recurrence of three similar events that were reported in Licensee Event Reports 79-36, 80-32, and 81-07.
This is a Severity Level IV violation.
RES PONSE:
We agree with the violation as stated above.
Upon discovery of the open Southeast Containment Spray Pump compartment door, it was immediately closed and dogged. All other watertight doors were then verified to be closed.
Full compliance was achieved at this time. A directive was issued to all personnel working in the area and an indoctrination session with all affected personnel was conducted on the requirements for the doors to be closed except during passage. All new personnel will be given the indoctrination. At present, there is an assigned individual working with the contractors assuring the doors are maintaf ued closed except during passage and each passage is logged.
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Mr. Eldon J. Brunner 4
September 21, 1981 As a further step to assure compliance, the supervisor of the job is personally checking the doors eac'a time the work crew departs the area, i.e., lunch break and end of day. The Engineering Department is currently designing a modification to provide a positive means of ensuring the continued closure of the doors in accordance with the Technical Specifications.
1he above actions concerning the compartment doors should assure compliance with the Technical Specifications until a more positive mechanism can be installed and made operable that will allow for ensuring closure or identification when door is open.
The overall subject of control of contractor activities at Oyster Creek is being reviewed and more positive means of control being implemented to eliminate the instances of violations occurring f rom these activities.
This concern is being addressed formally to the NRC in our response to the Notice of Violation dated August 21,1981 f rom Victor Stello, Jr. to Dr. S. Bartnoff.
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AT17CNENP 1
' 1.104', Rev. 4, 2/5/81 h
Dates 1
or Discovery Time:
DEVIATIN REPORP (See Reverse Side for Routing) 1.
Description of Deviation:
2.
Cm=ctive Acticm Taken:
3.
Notifications Made:
Plant Operations Manager Manager Operations Core Manager Director O.C. Operations Chmistry Marager Safety Review a nager Maintenance Manager NBC Direct Line Whn__ <-=1 S W ications AffecPM :
4 1
1 j
1 Sdinitted By/ Title
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4.
Evaltation:
Reportable Occ m :
Yes No T_==r14 a te 30 Day Safety Signif 4<-anee:
Yes No Reccanend PORC aaview:
Yes No Other (Describe Below):
Yes No Basis for Decision:
Other (Description):
i Plant Operations Myr./Date Safety Review Myr./Date Manager Operations /Date l
Note: Two (2) Signatures Required f
5.
Disposition:
I 5.1 RO # Assigned:
R@crt Due:
Report Aaaienwl 'Ib:
5.2 Engineering Task #-
s Assigned To.
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a 5.3 RO #:
Date to NRC:
Other Acticn nken:
ROUTnG:
Preparer:
Ctz:plete Sec. ions 1, 2, and 3 and formrd to Supervisor Preparer's Supervisor:
Fcrward to Plant Operations Manager Plant CWmticms.Dnager:
Cauplete Section 4 and forward to Manager Operaticus Manager Operations:
Concur and forward to Safety Faview Mnager Safety Review Manager:
Orplete Section 5.1 and forward to PCRC, or responsible snager Copy to PCRC (If Required)
Copy to Engineering Manager (If Required)
Engn % Manager:
0:xuplete Section 5.2 and return copy to Safety Review Manager Safety Review Manager:
Ctruplete Section 5.3 and file