ML20053E192
| ML20053E192 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 05/20/1982 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20053E187 | List: |
| References | |
| 50-219-82-06, 50-219-82-6, NUDOCS 8206070684 | |
| Download: ML20053E192 (3) | |
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APPENDIX A NOTICE OF VIOLATION GPU Nuclear Corporation Docket No. 50-219 Forked River, New Jersey 08731 License No.
DPR-16 Based on the results of the inspection conducted on March 17-19, 31 and April 1, 2, 5, 6, 1982 and in accordance with the NRC Enforcement Policy, 47 FR 9987 (March 9, 1982) the following violations were identified:
A.
Technical Specification 6.9.2 and Regulatory Guide 1.16 paragraph C.2.a.(2)(c) require a Licensee Event Report (LER) be submitted when the primary containment is degraded as evidenced by unacceptable containment leak rate type B or C test results.
Contrary to the above, no LER was submitted' identifying primary containment degradation evidenced by unacceptable containment leak rate type C tests results during a maintenance outage from February 7, until April 6, 1982, and also during the 1980 refueling outage.
This is a severity level IV Violation.
(Supplement I)
B.
Technical Specifications 6.8.1 and 6.8.3 require that written procedures be implemented and temporary changes not alter the intent of the original procedure.
Contrary to the above, the following are examples where approved procedures were not properly implemented and a temporary change altered the intent of the original procedure.
(1) On three occasions, February 28, March 17, and March 28, 1982, the licensee conducted leak rate tests on primary containment isolation valves NS03A, NS03B, V-1-106, and V-1-107 and did not determine the test results in accordance with specific instructions of Procedure 665.5.003. This resulted in the valves being found acceptable whereas, by procedure, their leakage exceeded the Technical Specification acceptance criteria.
(2) On March 28, 1982, while conducting a leak rate test on Main Steam Isolation Valve NSO4A, the valve packing was tightened without properly documenting this corrective maintenance activity on a Job Order Form as required by Procedure 105, Conduct of Maintenance.
(3) Primary Containment Leak Rate Test (PCILRT) Prucedure 666.5.007 requires that the test valve lineup be performed per the Valve Status Checkoff Sheets and the instruments be in their normal alignment per 8206070684 820520 PDR ADOCK 05000219 0
2 Procedure 410, Placing Instrument Racks RK-01,2,3,4 in Service.
On March 31, while conducting the PCILRT, valve V-38-1021 on the Valve Status Checkoff Sheet had not been verified to be open and the instrument alignment verification had not been started even though the test pressurization had started the previous day, March 30, 1982.
(4) PCILRT Procedure 666.5.007 requires personnel performing the test to sign the cover page to document the fact that precautions have been read and understood.
On March 31, 1982 no personnel had yet signed the cover page, although test pressurization started on March 30, 1982.
(5)_ PCILRT Procedure 666.5.007 requires the control room operator to log the reactor vessel flange temperature hourly during the test.
On April 2,1982, the day shift reactor operator was not logging the flange temperature as required and was not aware of the procedure requirement to do so.
(6)
Procedure 107, Procedure Control, requires that " Temporary Change" revisions to procedures be documented on a Station Controlled Distribution Document Request (Form 103-1) when executed.
On March 28, 29, 30,1982, four " Temporary Change" revisions had been executed in the working copy of PCILRT procedure 666.5.007 without being properly documented on the revision request / change Form 103-1.
(7)
Technical Specification 6.8.3 and Procedure 107 permit " Temporary Change" revisions to procedures provided they do not alter the intent of the original procedure.
On March 29, 1982 a " Temporary Change" revision was executed in PCILRT Procedure 666.5.007 which deleted the requirement to vent the Instrument Air System Piping inside the drywell.
The change altered the scope of the test i
boundaries and intent of the test procedure to measure the primary containment system overall leakage.
l This is a Severity Level IV Violation. (Supplement I) l l
Pursuant to the provisions of 10 CFR 2.201, GPU Nuclear Corporation is i
hereby required to submit to this office within thirty days of the l
date of this Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be l
achieved.
Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or a ffi rma tion.
Where good cause is shown, consideration will be given to extending your response time.
4
3 The responses directed by this Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
MAY Z 01982 wigimi signed Ws Jp)homasT. Martin, Director U
Division of Engineering and Technical Programs