ML20073D634
| ML20073D634 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 09/19/1994 |
| From: | J. J. Barton GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| C321-94-2153, NUDOCS 9409270350 | |
| Download: ML20073D634 (5) | |
Text
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i GPU Nuclear Corporation Nuclear
- eiter388 Forked River. New Jersey 08731-0388 609 971-4000 Writer's Direct Dial Number:
September 19, 1994 C321-94-2153 U.S. Nuclear Regulatory Commission Attention: Document Contro' Desk Washington, D.C.
20555
Dear Sir:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 Inspection Report 50-219/94-11 Reply to a Notice of Violation to NRC Inspection Report 50-219/94-11 contained two Notices of Violation. Attachments 1 and II to this letter contain the replies to the Notices of Violation, as required by 10 CFR 2.201.
If any additional information is required, please contact Mr. David Distel, GPUN Licensing, at 201-316-7955.
Sincerely,
{ I Vice President and Director John J.
arton Oyster Creek DJD Attachments c:
Oyster Creek NRC Project Manager Administrator, Region I Senior Resident Inspector E lv (,] ]
9409270350 940919 n
PDR ADOCK 05000219 y
PDR GPU Nuclear Corporation is a subsidiary of General PutAc UtAties Corporation
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t ATTACHMENT I VIOLATION 94-11-01:
"10 CFR 50, Appendix B, Criterion V (Instructions, Procedures, and Drawings), states, in part, Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria..
Contrary to the above, as of July 1, 1994, the static and dynamic motor-operated valve test procedures did not contain acceptance criteria.
The static test procedures did not specify conditions necessary for the test to be acceptable and the dynamic test procedures did not specify conditions necessary for returning the MOV to service."
GPUN REPLY:
GPU concurs with the violation as written.
REASON FOR VIOLATION Although MOV thrust " target values" were supplied to field personnel performing the test on computer generated data sheets, these values were generally not included with the test results and were not considered to be acceptance criteria. These values were utilized by field personnel to determine when-the MOVATS test data disk could be submitted'to Plant Engineering personnel for review and acceptance.
This informal method of determining acceptance developed oue to numerous ongoing changes to the acceptance criteria of the MOV's in the program caused by evolving issues in the generic MOV program.
In order to minimize the impact on procedure changes, we had previously removed the thrust targets from the formal acceptance criteria in the M0 VATS test procedure.
The previously discussed " target values" utilized the design verified, formally issued thrust values provided by Technical Functions Engineering personnel which were entered into a site operated computer calculation program that had been developed from the generic MOVATS methodology. The output of this computer program was the data sheet containing " target values" that Plant Engineerir.g provided to field personnel.
CQRRECTIVE ACTIONS TAKEN AND THE RESULTS ACHIEVED No immediate corrective actions were necessary since the " target values" provided to field personnel utilized verified, formally issued thrust values as input.
ATTAC MENT I" (CONT'D)
CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATIONS In order to further ensure the integrity of this data and to establish formal acceptance criteria that can be included with the field test packages, and to eliminate the need to perform subsequent data i
manipulations and calculations, GPUN has revised the MOVATS test procedure-to provide engineering generated " verified target values" to field j
personnel prior to testing. These " verified target values" utilize the design verified thrust values provided by Technical Functions Engineering as input to the site operated computer calculation. We independently verify that the design values have been correctly entered into the computer program as well as performing an independent verification of a computer generated calculation to verify the c puter program. The output values then become the " verified target values' that will be issued to the field personnel.
No additional calculations ill need to be performed later on the MOVATS trace.
The revised MOVATS Test Procedure (2400-GME 3918.54) also includes the appropriate level of engineering review required in order to consider a valve operable from a technical analysis standpoint, and requires an engineering signature to return the M0V to service. A "MOVATS Analysis i
Guideline" has been developed and will be used to perform the signature analysis on future static and dynamic tests. The guideline will specify the minimum thrust related conditions necessary for returning the MOV to service following a static or dynamic test. The guideline includes a method of extrapolating required thrust following a dynamic test at pressures below the calculated design basis and comparison with the dynamic test results.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED c
Full compliance was achieved on September 9, 1994 when the MOVATS Test Procedure, 2400-GME-3918.54, Revision 3 was issued as described above.
ATTACHMENT II j
i VIOLATION 94-11-02:
"10 CFR 50, Appendix B, Critarion III (Design Control), states, in part, The design control measures shall provide for verifying or checking the adequacy of design,... The verifying or checking process shall be performed by individuals or groups other than those who performed the original design...
Contrary to the above, as of July 1, 1994, the math operations utilized in the static and dynamic motor-operated valve test evaluations were not documented and there was no evidence that they were independently reviewed. There were also four identified cases where the same individual who signed the MOV signature analysis as
" analyst", also signed the test procedure indicating acceptability of the tests."
GPUN REPLY:
GPUN concurs with the violation, in part.
REASON FOR THE VIOLATION GPUN concurs with the first part of this violation stating that the math operations utilized in the static and dynamic test evaluations were not documented.
These math operations were performed during the data analysis process and involved only a comparison of design values to the data obtained during the test. These math operations were not considered part of design control measures.
GPUN does not concur with the second part of this violation that implies that design calculations were performed onsite that required subsequent design verification or independent reviews.
Formal design calculations were performed by Technical Functions Engineering and were design verified and entered into our formal configuration control data base.
The calculations or data manipulations performed onsite simply adjusted the design verified thrust values to include diagnostic equipment inaccuracies and torque switch repeatability tolerances. As such, they do not represent design calculations and are not subject to 10 CFR 50 Appendix B criteria for design verification or independent review. This is the reason that several " Reviewed By" blocks were unsigned.
As discussed in response to Violation 94-11-01 in Attachment I, we are enhancing the implementation of the OC MOV program and minimizing the potential for error by adjusting the design thrust values for diagnostic equipment inaccuracies and torque switch repeatability and verifying those values prior to generating the " target values". They will be formally included with the test packages as acceptance criteria, and the interpretation of the MOVATS test trace and comparison against these acceptance criteria will be independently reviewed arid signed-off by a qualified analyst.
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ATTACMENT II (CONT'D)
CORRECTIVE ACTIONS TAKEN AND THE RESULTS ACHIEVED
-No deficiencies were identified as a result of lack of documentation of the adjustment of design thrust values to include diagnostic equipment inaccuracy and torque switch repeatability. Therefore, no immediate corrective actions were necessary.
CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATIONS As discussed in response to Violation 94-11-01 in Attachment I, we have revised our nothodology to eliminate standard calculations involving test results.
Normal data manipulations and adjustments will be performed by the site operated computer program prior to testing the MOV. As described-in response to Violation 94-11-01 (Attachment I), inputs to the MOVATS computer program will be independently reviewed and the computer output will be checked to verify formulas were properly input.
Assessments or unique calculations performed on the test data will be documented, i
i DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved on September 9, 1994 when the MOVATS Test Procedure, 2400-GME-3918.54, Revision 3 was issued as described in response to Violation 94-11-01.
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