ML20039E269

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Responds to NRC Re Violations Noted in IE Insp Rept 50-219/81-18.Corrective Actions:Prodecure 106 Will Be Revised to Include Procedure Compliance Section
ML20039E269
Person / Time
Site: Oyster Creek
Issue date: 12/17/1981
From: Phyllis Clark
JERSEY CENTRAL POWER & LIGHT CO.
To: Keimig R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20039E268 List:
References
NUDOCS 8201070090
Download: ML20039E269 (6)


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i Jersey Central Power & Light Company Madison Avenue at Punch Bowl Rcad Morristown, N0w Jersey 07960 (201)455-8200 December 17, 1981 0

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Mr, R. R. Keimig, Chief Projects Branch No. 2 Diviwi t ti of Resident and Project Inspection

. U.S. Nuclear Regulatory ' o:cmission Region 1 631 Park Avenue King of Prussia, PA 19406 1

Dear Mr. Keimig:

Subject:

Oyster Creek Nuclear Generating-Station Docket No. 50-219 Inspection No. 50-219/81-18 In accordance with the provisions of 10 vFR 2.201, this letter presents our response to the Notice-of Violation regarding the inspection conducted by Mr. J. Thotr.as on September 15 - October 5,1981.

. Enclosed are our responses to the specific violations. _If there are

-any questions regarding t:-a enclosed information or additional-information i

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is required, please contact me or Mr. Michad Laggart of my staff at (609) 693-6932.

Very truly yours, g

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Philiph.// Clark i

'Vice-Ptesident - Nuclear Central Power & Light Co.

Jersey,ive Vice-President I

Exec'ut GPU N,uclear i

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Sworn to and subscribed to before me this I Y'7 M day of L/%,

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Notary Public O

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Jersey Central Power & Light Cornpariy is a M$t@N!f!$ddffEaM8b5' Nties System =

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e Mr. R. R. Keimig Page 2 cc:

Mr. Ronald Haynes, Administrator Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.

20555 NRC Resident Inspector Oyster Creek Nuclear Generating Station Forked River, NJ 08731 9

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ENCLOSURE Inspection No. 50-219/81-18 The following information provides a response to the violation contain<:d in the U.S. Nuclear Regulatory Commission letter of November 12, 1981.

Violation A:

' Technical Specification 6.8.1 stater, in part, " Written procedures shall be

' established, implemented, and caintained..."

Procedure 106, Revision 18, dated August 4, 1981, " Conduct of Operations,"

- requires, in part, that: "... a proper and orderly shif t turnover be accomplished... Further, the oncoming Group Operating Supervisor shall review-and sign the Group Shift Supervisor Turnover Checklist and tae Control Room Turnover Checklist and shall record the Group Shift Supervisor's Log...

a) Those items required by the Shift Turnover procedure... Additionally, the control room operator shall record in the Control Room Log... a' Those items required by the Shif t Turnover procedure.

Contrary to the above, on September 29, 1981, the on-shif t Group Operating Supervisor relieved one Control Room Operator of his duties for one hour and 42

_. minutes.

Another qualified individual assumed the duties of Group Operating Supervisor and failed to conduct a shift turnover. Further, no log entries

_. were made indicating transfer or responsibi'.ity from one individual to the other.

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Response

The violation is correct as stated.above. The immediate corrective action j

effected by the Operations Manager was to reinstruct the individuals involved l

in the proper method of shift turnover (as delineated by Procedure 106 " Conduct of Operations"). All licensed operators will be required to read the Notice of

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Violation and response, and review the appro:-riate sections of Procedure 106 dealing with shifLt tu_r_nover by December 31, 1981.

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The Director of Station Operations has issued a memorandum to station management reiterating the established requirements that all station personnel follow. written procedures; that any procedure inadequacies identified be resolved: and that appropriate action be taken against any individual or-organization observed not complying with procedures.

In order to insure continuity of management's position, Procedure No. 106 will be revised to' include a "r 'ocedure ' compliance sec tion".

This revision is expected to be issued by December 31, 1981. The corrective actions we have taken should

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ensure that future violations in this area will not occur.

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ENCLOSURE Page 2 Inspection 50-219/81-18 Violation B:

10 CFR 50, Appendix B, Criterion XI, " Test Control" states, in part, "A test

- program shall be established to assure that all testing required to demonstrate that... systems... will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the...

acceptable limits contained in applicable design documents..."

The Oyster Creek Nuclear Generating Station Operational Quality Assurance Plan, Revision 5, dated April 1, 1981, Section 1I.2, " Test. control," states,.in part, "E.

All testing required by... Operating Technical Specifications... shall be performed in accordance with written, approved procedures. During a procedure preparation, the following items, as a minimum, will be evaluated for applicability and inclusion:..

14.

Test acceptance limits... F.

Testing and test procedures shall teet the requirements of all applicable codes, standards, and regulatory requirements..."

Technical Specificatio'n 4.7.B, " Station Batteries," states, in part, "1.

Weekly surveillance will be performed to verify the following:

c.

The overall battery voltage 'is greater than or equal to 120 volts (Diesel battery; 112 volts).

d.

The pilot cell specific gravity, corrected to. 77 F is greater than or equal to 1.190.

2.

Quarterly surveillance will be perforced to verify the following:... c.

The specific gravity, for each cell, is 0

-- - greater than or equal to 1.190 when corrected to 77 F...

3.

At least once per 18 months b.

Battery low voltage annunciators are verified to pick up at 115 volts +1 volt and to reset at 125 volts +1. volt (Diesel 112 volts +1 volt)."

Contrary to the above, station battery surveillance procedures do not conform to these requirements in that:

1.

Procedure 634.2.002, Revision 5, June 30, 1980, " Main Station Weekly Battery Surveillance," specifies an overall battery voltage of. greater

._ _ than 105 volts.. _ _ i. _

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2.

Procedure 636.,2.005, Revision 4, June 30, 1980, " Dies,el Generator Weekly.

Battery Surveillance," specifies an overall battery voltage of greater c.han 98 volts.

3.

Procedures 634.2.003, Revision 4, January 10, 1980, " Main Station Battery Monthly Surveillance;" 636.2.006, Revision 3, June 20, 1980, " Diesel Generator Monthly Battery Surveillance;" and the two previous referenced 0

procedures do not specify correcrion of specific gravities to 77 F.

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No procedures have been implemented to test the battcry low. voltage am.unciators'since the addition af this requirement to Technical specificatiens by Amendmer.t 55, dated August. 13, 1981, to Facility i

Operating License DPR-16.

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ENCLOSURE Page 3 Inspection 50-219/81-16

Response

The violation is correct as stated. The corrective action, with regard to the specific nonconforming procedures referenced above in Items 1 through 4, is as follows:

Item 1:

Procedure No. 634.2.002 " Main Station Weekly Battery Surveillance" was temporarily changed, upon identification of the violation to station management, to specify that the overall battery voltage shall be greater than 120 volts and the specific gravity corrected to 77 F.

A permanent revision to this procedure was effected on October 28, 1981.

Item ?.

Procedure No. 636.2.005 " Diesel Generator Weekly Battery Surveillance" was temporarily changed, upon identification of the violation to station managemet-t, to specify that the overall battery voltage shall be greater than 112 volts anii the specific gravity corrected to 77 F.

A permanent revision to this procedure was ef fected on October 28, 1981.

Item'3:

Procedure 634.2.003 "Mai.: Station Battery Monthly Surveillance" and ProccJure 636.2.006 " Diesel Generatur Monthly Battery Surveillance" were cemporarily changed prior to conducting the required surveillances to reflect the correction of specific gravities to 77 F.

Pe rmanent revisions to the procedures were effected on October 28, 1981.

Item 4:

The. low voltage alarm will be checked during the 18 month battery capacity test.

Tne procedure for conducting this test anu the test of the alarm will be changed prior to conducting the discharge test.

The battery capacity discharge test is currently sche /uled for the upcoming refueling / maintenance outage.

It shall be noted that the battery performpnce 6oc tmented during surveillance testing met or exceeded the requirement. af the Technical Specifications.

The requirement to correct the specific gravity to 77 F was not documented but is standard practice among electricians conducting the testing.

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ENCLOSUEr Page 4 Inspection 50-219/81-18 With regard to the repetitive nature of this violation, we feel that

..o additional procedural controls are required to assure that a repeat of this type of violation does not occur. The distribution of the Technical Specification Amendment to key personnel was done promptly and the individual assigned to revise the su:vaillance procedures was fully aware of his responsibility to do so.

The assigned individual reviewed the surveillance procedures involved and made an incorrect determination that they satisfied the testing requirements of

-'ik T echnical Specifications. The individual involved has been reinstructed in the need to assure compliance to Technical Specification testing requirements.

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