ML20059K896

Responds to Violations Noted in Insp Rept 50-219/93-81. Corrective Actions:Personnel Assigned to Perform Independent Safety Reviews of LERs Issued in 1992 & 1993

ML20059K896
Person / Time
Site:	Oyster Creek
Issue date:	01/24/1994
From:	J. J. Barton GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
C321-94-2010, NUDOCS 9402020330
Download: ML20059K896 (3)

Text

g-s i

GPU Nuclear Corporation

- 0 Nuclear

=' n:r ""

Forked River, New Jersey o8731-o388

-l 609 971-4000 i

Writer's Direct Dial Number:

l 1

C321-94-2010 i

January 24, 1994 U.S. Nuclear Regulatory Commission i

Attn: Document Control Desk Washington, DC 20555

Subject:

Oyster Creek Nuclear Generating Station Docket Number 50-219 Response to Notice of Violation

{

Pursuant to the provisions of 10 CFR 2.201, the enclosure provides GPU Nuclear Corporation's response to the Notice of Violation contained in the.NRC Region 1 Operational Safety Team Inspection (OSTI) Report No. 50-219/93-81 transmitted by letter dated December 23, 1993.

GPU Nuclear Corporation (GPUN) has and continues to develop and implement initiatives focused on establishing continuous improvement in performance.

It is gratifying to see in the inspection report that overall performance improvement has been recognized-since the Diagnostic Evaluation Team

. Inspection. GPUN also recognizes the NRC Team's observations in those areas needing additional attention and greater effort in correcting weaknesses noted i

in the report. At some point in the future. GPUN representatives will be

~

contacting NRC Region 1 personnel to arrange a meeting to review the inspection results and GPUN's actions to address areas for improvement i

identified in the report.

j If you should have any questions.or require additional information please contact Mr. George Busch of my staff at 609-971-4643.

-- [

Very ru you" L

270%0

. nn a,

.rton o

ice Pr ident and Director Dyster Creek GWB/jc Enclosure cc:

Administrator', Region 1

[/((/

r Senior NRC Resident Inspector l

Oyster Creek NRC Project Manager j

/

n I

940202o33o 940124 ADOCK 0500 9

gDR GPU Nuclear Corporation is a subsidiary of General Pubhc Utikties Corporation

m.

Page 1 of 2 l

C321-93-2010 I

Enclosure Violation: Technical Specification 6.5.2.5.d, requires, in part, that i

violations and reportable events shall receive Independent Safety Reviews (ISRs).

Contrary to the above, on September 29, 1993, all NRC violations and ten licensee event reports (LERs) issued in 1992 and 1993 did not receive the required independent safety reviews.

-l

Response

GPUN concurs with the violation except for the number of LERs involved. Of the ten cited four were not assigned to qualified reviewers. Three of the ten were assigned but had not been completed in a reasonable time frame and GPUN agrees this is a weakness. However, the remaining three were LERs that required a supplemental report.

ISRs cannot be performed on these since the i

purpose of the review includes consideration of the "results of any investigations made and the recommendations resulting from such investigations to prevent or reduce the probability of recurrence of the event".

This cannot be accomplished until the supplemental report has been developed which includes the results l

of investigations and any recommendations made. GPUN does concur that-supplemental reports are not always timely and actions are being taken to improve this process.

t The violation is a result of personnel error in not properly j

assigning ISRs of four LERs and deficient instructions regarding required reviews of violations. Additionally, a weakness exists in assuring timely review of LERs and timely submittal of supplemental reports.

Immediate corrective actions were taken to address the noncompliance. These actions included assigning personnel to i'

perform ISRs on those LERs that previously were not assigned, assigning personnel to perform ISRs on violations occurring in 1993, and initiating a critique to determine the cause of the occurrence and develop long term corrective actions +, prevent t

recurrence. These actions have resulted in completic' LT ISRs on all LERs identified above with the exception of those Lt?

requiring a supplemental report. Of the th i' LERs requn ing supplemental reports, two have been complet 1 is well as the ISRs and the third is awaiting engineering input

afety reviews of 1993 violations have been completed.

I i

l

l Page 2.of 2 C321,94-2010

.e Enclosure (Cont'd) 1 Long term corrective actions consist of revising licensing instructions to require assignment of personnel to perform ISRs on l

violations; revising department procedure (5000-ADM-1291.02) to require ISRs on violations, deviations, and reportable events; and to develop a change to the Technical Specifications to remove the t

requirement for ISRs on violations since numerous redundant reviews are conducted.

t Additionally, the critique was assigned as required reading for j

all licensing personnel. All of the above actions have been completed with the exception of the change to the Technical i

Specifications which is in preparation with an expected submittal i

date of July 1, 1994. Regarding timeliness of-reviews and submittal of supplemental reports, departmental directives have i

been issued to define acceptable bases for extending due dates and

.j department instructions will be revised to require submittal of l

LER supplemental reports by the date provided in'the report or to notify the NRC of a delay and the new submittal date.

It is

j expected that these actions will prevent recurrence of this violation in the future.

i Full compliance with the regulations was' achieved on 1

January 24, 1994.

W i

t J

1 e

i t

r I

-)

.i f

?