ML20080R753

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Responds to Violations Noted in Insp Rept 50-219/94-29. Corrective Actions:Valve Operators Properly Adjusted & post-maint Testing Performed
ML20080R753
Person / Time
Site: Oyster Creek
Issue date: 03/06/1995
From: J. J. Barton
GENERAL PUBLIC UTILITIES CORP.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
C321-95-2088, NUDOCS 9503100062
Download: ML20080R753 (3)


Text

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GPU Nuclear Corporation Nuclear  :::eNSE **

Forked River, New Jersey 08731-0388 609 971-4000 Writer's Direct Dial Number:

C321-95-2088 March 6, 1995 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Dear Sir:

Subject:

Oyster Creek Nuclear Generating Station l Docket No. 50-219  ;

Reply to a Notice of Violation l (Inspection Repon 50-219/94-29) l In accordance with 10 CFR 2.201, Attachment I provides GPU Nuclear's reply to the Notice l of Violation as documented in the subject Inspection Report. l If you should have any questions or require further information, please contact Brenda .

DeMerchant, Oyster Creek Licensing Engineer at 609-971-4642. i Since 1 ours,

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J3hn J. a tn ,

ice P es' tent and Director l

. Oyster reek JJB/BDFJjc cc: Administrator, Region 1 Senior NRC Resident Inspector Oyster Creek NRC Project Engineer 9503100062 950306 PDR

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-.io ll L' ' U GPU Nuclear Corporation is a subsidiary of General Pubhc Utikties Corporation / l

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C321-95-2088 Attachment I

.Yhdclinn-Technical Specification 6.8. (Procedures) states that written procedures shall be established,

-implemented, and maintained that meet or exceed the requirements of NRC Regulatory Guide 1.22, " Quality Assurance Program Requirements (Operation)," including procedures for performing maintenance.

C000-WMS-1220.08, " Job Order," requires that the job supervisor coordinate with the planner orjob coordinator if the job scope changes and/orjob order revisions are required.

Contrary to the above, during a repetitive maintenance activity (Job Order 56488) on September 25,1994, and November 3,1994, the job supervisor did not coordinate with the planner or job coordinator when work that was outside the scope of the job order was perfonned on two drywell ventilation exhaust valves V-27-1 and V-27-2. As a result, the

- appropriate post-maintenance test was not performed, and valves V-27-1 and V-27-2 were later determined to be inoperable.

GPUN Realv GPUN concurs with the violation as written.

This occurance was also documented in Licensee Event Report (LER)94-022 which was submitted to the NRC January 18,1995.

Reason for the Violation The cause of the violation was a failure to follow established procedures for the control of maintenance activities. This was attributed to a less than adequate understanding by the-maintenance personnel of the requirements related to changes in the scope of work that would have invoked additional work instructions and post maintenance testing requirements.

Contributing causes for the violation were inadequate verbal & written communication, attention to detail, and followup. The supervisors involved exercised poor judgement by not identifying the additional activities as a major scope change to the job order.

Corrective Actions Taken and the Results Achieved Upon discovery of the deficient condition of the valves, immediate corrective actions were taken to obtain proper adjustment of the valve operators, and perform the appropriate post maintenance testing. Valve operability was established in compliance with Technical Specifications.

Corrective Steps Taken to Avoid Further Violations A special GPUN Assessment Team comprised of personnel from various GPUN functions and .

with varied backgrounds including maintenance was convened at the request of the Director, )

Oyster Creek. A bmad and comprehensive evaluation of the event was conducted including root cause determination and recommended corrective actions.  ;

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' C321-95-2088 -

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I Attachment I (Continued) l I

Corrective Steos Taken to Avoid Further Violations (Continued)

Corrective actions were expeditiously implemented to assure maintenance personnel were 1

- fully awam of the event and the administrative mquirements which apply .to work scope j changes. In parallel _with the Assessment Team's investigation, a specific Maintenance critique of the event was conducted. Timely communication ofinformation necessary to avoid any additional occurrences was completed. In addition, personnel not associated with this event -

were interviewed to gain further assurance that administrative controls are understood by j others in the Maintenance organization.  !

. I Additional measures have been or will be taken to assum the event and lessons learned are-fully understood by maintenance and station personnel-  ;

  • The Site Director pmvided written communications to all station personnel reaffirming i his and the Company's expectations of compliance with Policies, Standards, and . 1 Procedures.
  • The Plant Maintenance Director provided his review of the event, that of the Assessment Team and that of the Maintenance Critique, to each supervisor emphasizing l managements expectation for compliance to procedumi controls.
  • Training of all maintenance craft personnel is underway to resensitize them to the  !

importance of compliance to procedures, and the administrative requirements that apply to changes in the work scope forjob orders. This training is expected to be completed  ;

by March 31,1995.  !

  • The Plant Maintenance Director is conducting face to_ face discussions with each first i line supervisor to discuss this event, the need to comply with procedures and to  !

emphasize Maintenance Managements' expectations with regard to the ownership and l accountability aspects associated with carrying out their job responsibilities.

i Date When Full Comoliance was Achieved i Full compliance was achieved on December 19,1994 when V-27-1, and V-27-2 were i successfully adjusted, local leak rate tested, and stroked closed.  !

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