ML20059B623

Forwards Insp Rept 50-219/93-81 on 930927-1015 & Notice of Violation

ML20059B623
Person / Time
Site:	Oyster Creek
Issue date:	12/23/1993
From:	Cooper R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	J. J. Barton GENERAL PUBLIC UTILITIES CORP.
Shared Package
ML20059B627	List: IR 05000219/1993081 ML20059B623 ML20059B633
References
EA-93-285, NUDOCS 9401040199
Download: ML20059B623 (5)

See also: IR 05000219/1993081

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DEC 2 31993 q

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Docket No. 50-219 i

l EA 93-285 j

l Mr. John J. Barton l

l Vice President and Director l

GPU Nuclear Corporation j

Oyster Creek Nuclear Generating Station  !

P.O. Box 388  :

Forked River, New Jersey 08731 l

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Dear Mr. Barton:

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SUBJECT: NRC REGION I OPERATIONAL SAFETY TEAM INSPECTION

L NO. 50-219/93-81

An NRC team, led by Mr. Paul Kaufman, conducted an Operational Safety Team Inspection

(OSTI), on September 27 through October 15,1993, at your Oyster Creek Nuclear

Generating Station, in Forked River, New Jersey, and at your corporate office in Parsippany,

New Jersey. After this inspection on October 30,1993, Mr. Kaufman and I discussed the

inspection findings with you and members of your staff at an exit meeting that was open for

public observation. This letter forwards the OSTI inspection report and findings of the

inspection. i

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The purpose of this inspection was to determine the effectiveness of the Oyster Creek

organization in the identification, evaluation, and resolution of performance deficiencies that

could affect safe plant operations at Oyster Creek. The inspection was conducted as a result

of an observed decline in performance of work practices ad equipment reliability over the j

past SALP period. In addition, we wanted to assess the ir.itiatives that Oyster Creek i

, management implemented in the engineering and maintenance / surveillance areas to address

I the NRC Diagnostic Evaluation Team (DET) inspection findings. Thus,- the focus of this

inspection was in the engineering and maintenance / surveillance areas and the effects of

management and corrective actions on performance in those areas.

Based on the results of this inspection, we conclude that Oyster Creek's overall performance

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has improved in certain areas, with a number of notable strergths, since the DET inspection

that was conducted in December 1990. Specifically, some of the strengths noted during the

inspection were that quality assurance (QA) audits and operational QA group activities are

being'used effectively as a management tool to assess performance; effective communications

l~ among organizations is improving licensed activities; and, management is effectively involved

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9401040199 931223

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DEC 2 31993

Mr. John J. Barton

in the day-to-day operation of the facility. Additional strengths are identified throughout the

enclosed inspection report. We observed a sense of dedication, ownership, and

accountability in the GPUN organization at Oyster Creek and we are encouraged by your

general progress and overall improving trend in the areas inspected.

However, we identified a significant weakness in the operability and reportability

determination process that warrants your attention to assure that plant deficiencies are

properly evaluated and expeditiously justified. A similar programmatic weakness dealing

with operability determinations, identified during the DET inspection, was not corrected, and

the deficiencies recurred. The technical operability justifications, when completed, did not

indicate the inoperability of any safety-related plant equipment. Nonetheless, we are

particularly concerned about the lack of guidance and processes for ensuring adequate and

timely operability determinations are conducted, when degraded or nonconforming conditions

are encountered.

Also, we determined that weaknesses still exist in some areas that require performance

improvement and additional focus by station management. In particular, we noted that: 1)

Oyster Creek operations personnel do not routinely enter technical specification (TS) limiting

conditions for operation (LCOs) when the performance of a surveillance test renders

equipment inoperable; 2) supplemental licensee event reports (LERs) are not being submitted

in a timely manner; and, 3) in some instances, inadequate action has been taken regarding

review of industry operating experience information. Aggressive management attention is

needed to address the team's conclusion that: 1) the operating practice of not entering a TS

LCO action statement, when equipment is removed from service and is inoperable, is

contrary to the guidance provided in NRC Generic Letter 91-18; 2) an overall delay exists in

the LER process for identifying the root cause and corrective action for events which has

resulted in the inability to evaluate and submit supplemental LERs; and, 3) industry identified

deficiencies that potentially exist at your facility need to be promptly assessed and

justifications properly documented to establish continued operability of the equipment or

component.

In addition, one apparent violation was identified and is being considered for escalated

enforcement action in accordance with the " General Statement of Policy and Procedure for

NRC Enforcement Actions" (Enforcement Policy),10 CFR Part 2, Appendix C (1993). The

apparent violation concerns a number of occasions during which you operated the plant

outside the plant Technical Specifications core design limits, while conducting core spray

system surveillance testing. We are concerned because your failure to adequately monitor

the average planar linear heat generation rate (APLHGR) went unrecognized since September

5,1991, when Technical Specification Amendment 153 was implemented. Also, failure to

take appropriate corrective actions to a safety issue once this condition was identified to your

management staff on October 1,1993, resulted in a subsequent violation of this condition

OFFICIAL RECORD COPY

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DEC 2 31993 '

Mr. John J. Barton 3

I during performance of a core spray system surveillance test on October 5,1993.

l Accordingly, no Notice of Violation is presently being issued for this inspection fm' ding.

Please be advised that the number and characterization of apparent violations described in the ,

enclosed inspection report may change as a result of further NRC review.

We will contact you separately to schedule an enforcement conference to discuss this  !

l apparent violation. The enforcement conference will be closed to public observation. The

purposes of this conference are to discuss the apparent violation, its cause and safety signifi- >

cance; to provide you the opportunity to point out any errors in our inspection report; to ,

provide an opportunity for you to present your proposed corrective action; and to discuss any

l other information that will help us determine the appropriate enforcement action in

accordance with the Enforcement Policy. In particular, we expect you to address how and -

why this condition went unrecognized since your Topical Report 053, " Thermal Limits With

One Core Spray Sparger," dated December 1988, clearly established the need to implement a

core thermal limit penalty. Although your technical specifications were not amended until

1991, the important core operating parameters, such as core limitations should have been

translated into the applicable surveillance procedures after your Topical Report was issued.

In addition, this is an opportunity for you to provide any information concerning your

perspective on (1) the severity of the issue, (2) the factors that the NRC considers when it

determines the amount of a civil penalty that may be assessed in accordance with Section IV.

l B. 2 of the Enforcement Policy, and (3) the possible basis for exercising discretion in

accordance with Section VII of the Enforcement Policy. You will be advised by separate ,

correspondence of the results of our deliberations on this matter. No response regarding the [

apparent violation is required at this time.

Further, one of your activities appeared to be in violation of NRC requirements, as specified

in the enclosed Notice of Violation (Notice). Specifically, a violation was identified

involving your failure to conduct independent safety reviews of NRC violations and licensee

event reports (LERs), as required by the Oyster Creek Technical Specifications.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. In your response, you should document the ,

specific actions taken and any additional actions you plan to prevent recurrence. After

receiving your response to the Notice, including your proposed corrective actions and the

results of future inspections, the NRC will determine whether further NRC enforcement

action is necessary to assure compliance with NRC regulatory requirements. ,

The response directed by this letter and the enclosed Notice is not subject to the clearance

procedures of the Office of Management and Budget as required by the Paperwork Reduction

Act of 1980, Pub. L. No. 96.511.

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OFFICIAL RECORD N  !

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DEC 2 31993 ,

Mr. John J. Barton 4

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Your cooperation is appreciated.

Sincerely,

ggg s!GNED BY:

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Richard W. Cooper, II, Director

Division of Reactor Projects

Enclosures:

1) Notice of Violation '

2) NRC Operational Safety Team inspection Report 50-219/93-81

cc w/encls: .

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M. Laggart, Manager, Corporate Licensing

P. Czaya, Acting Licensing Manager, Oyster Creek

Public Document Room (PDR) ,

local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

T. Martin, Regional Administrator i

W. Kane, Deputy Regional Administrator

K. Smith, Regional Counsel

D. Holody, Enforcement OfGcer

J. Lieberman, Director OE ,

J. Goldberg, Deputy Assistant General Counsel for Enforcement, OGC

L. Callan, Acting Associate Director for Projects, NRR ,

K. Abraham, PAO (2)  :

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NRC Resident Inspector

State of New Jersey

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DEC 2 31993

Mr. John J. Barton 5

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bec w/encis:

Region I Docket Room (with concurrences) ,

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bec w/cncis (VIA E-MAIL):  !

W. Dean, OEDO .

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J. Stolz, NRR/PD 1-4  ;

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A. Dromerick, NRR/PD 1-4

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