ML20070T391
| ML20070T391 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 03/29/1991 |
| From: | J. J. Barton GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| C321-91-2074, NUDOCS 9104040150 | |
| Download: ML20070T391 (4) | |
Text
GPU Nuclear Corporation J Nuclear
- ors:r388 Forked River, New Jersey 087310388 609 971 4000 Wnter's direct Dial Number.
March 29, 1991 C321-91-2074 U.S. Nuclear Regulatory Commission Attn Document Control Desk Washington, D.C.
20555 Dear Sira Subject Oyster Creek Nuclear Generating Station Docket No. 50-219 Inspection Report 91-01 Reply to a Notice of Violation In accordance with 10 CFR 2. 201, the enclosed provides GPU Nuclear's response to violation A identified in NRC's Inspection Report 50-219/91-01.
As stated in the cover letter of our response to violation B dated March 18, 1991, an extension of the due date for violation A was granted by your staff on Friday, March 15, 1991.
If further information is required, please contact Brenda DeMerchant, OC Licensing Engineer at (609)971-4642.
Very truly yours,
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1 ie or, Oyster Creek JJB/BDeH/jc cci Administrator, Region I Senior NRC Resident Inspector Oyster Creek NRC Project Manager i
I 9104040150 910329 h
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GPU Nuclear Corporahon is a subsidiary of General Pubhc Utates Corporation Ik
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-i "c321-91-8074 Page 1 5-Violation A.
10 cFR 50.49 requires that environmental _ qualification of electric equipment important to safety that are relied upon to remain 1 functional during and following a. design basis event shall be established.
A. record of qualification documentation must be maintained in an auditable form.
Contrary to tha above, on December 13, 1990, the environmental qualificat'>n of electric splicob in the core spray pumps P-20-2A, P-20-2c, and containment spray pumps P-21-1A and P-21-1B was not established in that the splices were different from the ones recorded in the licensee's qualification documentation.
Additionally, auditable documentation was not maintained which indicates the type of splices that exist on core spray pump P-20-1B motor leads.
This violation is severity level IV (Supplement 1).
Responses s
~ 1. - GPUN concurs with the violation as stated, however we disagree with a statement in the cover letter of the subject inspection report which states "We are concerned about the first violation because it was not addressed after
~
- identification in February 1990, and it may show weakness in the equipment qualification program".
In addition we also disagree with a statement on page 8 of the inspection report which states "no operability determination was
-completed _and corrective action had not been implemented before December,
~1990.
-In late 1989,-the Environmental Qualification (EQ) group was. asked to review and provide input on splices in core spray booster pumps P-20-2A, P-20-2c and containment spray pumps P-21-1A, P-21-1B,Jin support of planned maintenance activities.
As a result of this inquiry, the EQ group identified inconsistencies in.the baseline-data for the four splices in question which prompted a request for inspections to 1) obtain data necessary to obtain replacement splice kits and 2) to attempt to verify by visual inspection that the" splices were what had been identified and qualified in the 1985-1986 time
-frame and to replace the splices, if necessary. These inspection requests (job orders) were submitted on 12/19/89 and were to be conducted during an outage of sufficient duration or during.the 13R refueling outage..
Splices P-21-1A and P-21-1B were inspected on 2/7/90 and dispooltioned on s2/9/90.
However, due to miscommunications the fact that motor splices P-20-2A and P-20-2c had been inspected and closed out at the site on 2/9/90 was not!
- evident to the IX) group until 12/10/90. On 12/12/90 the EQ group determined that a deviation ~ existed and' a determination of operability. was issued on
-12/13/90 for both splices.
On 12/15/90 splice P-20-2c was replaced with a
. qualified splice.
C321-91-2074 Page 2 2.
Reason for the Violation When CPUN first began compiling the EQ master 'ist in 1985-:)86, it was obvious that a 100% walkdown of all applicable components in the plant would be impractical. Therefore by using a combination of procurement records, modification records, vendor information and representative walkdowns, ' ta was gathered to determine the manufacturer and model number of components required to be qualified as part of the EQ master list.
While GPUNs program provides reasonable assurance that the auditable EQ documentation represents the plant configuration it is not predicated on verification walkdowns for all components.
A reinspection of the splice for P-20-1B verified that the auditable documentation (i.e., the EQ file) on the splice was accurate.
During the early phases of the Oyster Creek EQ Program; i.e.,
1985-1986, the tape splices for twelve EQ pump motors were uniquely identified as being original construction splices consisting of specific organic material which was qualified in accordance with EQ Pile OC-388.
This file was reviewed in 1986 as part of the 86-08 innpection for 10 CFR 50.49 complianco.
Included within this group of twelve splices are the four splices referenced in Violation A of Inspection Report 91-01.
Since these twelve splices are the only large motor lead splices on the EQ Master List, they have been programmatically viewed as a unique group and were qualified as such.
Additionally, as a result of our 1986 inspections, GPUN identified tape splices associated with five EQ components.
All these tape splices were re.aoved in 1986 during the 11R refueling outage.
The EQ File was revised and programmatic controls were implemented to prohibit the future use of tape splices within the EQ program.
GPUN therefore believes that the unique nature of this finding along with existing program requirements indicate that additional plant walkdowns are not warranted.
Since the inception of the EQ program in November, 1985 there has not been a significant number of deviations where equipment was determined to be different than that which was established by the EQ file.
All self identified issues have been systematically addressed, corrective actions have been implemented and a determination was made that no safety significance was associated with these items.
3.
Corrective Steps that have been Taken and the Results Achieved:
Hotor splice P-20-2C was replaced with a qualilled heat shrink splice on 12/15/90.
Splices P-20-2A, P-21-1A and P-21-1B were replaced during the current 13R refueling outage.
The remaining eight motor splices will all be inspected during 13R to verify that they are what is identified in the EQ file. Any splices that are not qualified will be replaced prior to restart.
This will address all twelve of the splices described in this response prior to restart from the 13R outage.
~_, -.. _ - -
1 C321-91-2074 l
Page 3' 4.
Corrective Steps that will be taken to Avoid Further Violationn GPUN will review the EQ program to determine what new items would be prudent to add as an extension of the existing computerized engineering data base.
Introducing this level of control will enhance the future identification, control and documentation related to these itema.
In this way EQ component configuration will be more readily understood and maintained, likewise-potential deviations will be addressed mcre efficiently.
An evaluation of the process to identify and correct EQ deficiencies is being conducted.
This evaluation focuses on responsibilities, interfaces, work authorization systems, document closeout and overall effectiveness.
The results of this evaluation will be reviewed for potential program improvemente as well as EQ training of the appropriate personnel as required.
5.
Date When Full comoliangg Will Be Achieved:
1 Full compliance was achieved on 3/26/91 when motor splices P-20-2A, P-21-1A and P-21-1B were replaced with qualified splices.
As stated earlier, P-20-2C was replaced with a qualified heat shrink oplice on 12/15/90.
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