ML20081D108

Responds to NRC Ltr Re Violations Noted in Insp Rept 50-219/94-24.Corrective Actions:All Activities on EDG Suspended & Review Team Formed to Assess Condition & Determine Actions

ML20081D108
Person / Time
Site:	Oyster Creek
Issue date:	03/16/1995
From:	J. J. Barton GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
C321-95-2084, NUDOCS 9503200131
Download: ML20081D108 (7)

Text

m- i i

l 9

GPU Nuclear Corporation U iuolear m',f;'g;388 Forked River.New Jersey 08731-0388 609 971-4000 Writer's Direct Dial Number:

March 16,1995 C321-95-2084 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Subject:

Oyster Creek Nuclear Generating Station Docket No. 50-219 Inspection Report 50-219/94-24 Reply to a Notice of Violation NRC Inspection Report 50-219/94-24 contained three violations of NRC requirements.

Attachments I and II to this letter contain the replies to the cited Problem and Violation respectively as required by 10 CFR 2.201.

If you should have ar.y questions or require further information, please contact Mr. Terry Sensue, Oyster Creek Licensing Engineer at 609-971-4680.

Sincer ly you s, f

1 j ( $14-.

'Jotn J. Qtrton Vi e President and Director yster Creek JJBiTS/jc cc: Administrator, Region 1 Senior NRC Resident Inspector Oyster Creek NRC Project Engineer i

9503200131 950316 PDR ADDCK 05000219 Q PDR

// {

GPU Nuclear Corporation is a subsidiary of the General Pt.blic Utilities Corporatioh

4 .'

, C321-95-2084 Page.1 of 4 ATTACHMENT 1 Pmblem A. 10 CFR Part 50, Appendix B, Criteria III, Design Contml, requires, in part, that measures be established to assure the applicable regulatory requirements and the design basis for those stmetures, systems and components to which Appendix B applies are correctly translated into specifications, drawings-procedures and instmctions. The design control measures shall pmvide for verifying or checking the adequacy of design, such as by the performance of. _

design reviews. In addition, design changes, including field changes, shall be subject to design control measures commensumte with those applied to the original design.

Contmry to the above, between September and December 1994, design modifications were performed to the emergency diesel generators, stmetures, systems and components to which Appendix B applies, and the applicable-design basis was not correctly translated into specifications, procedures and instmetions (modification documents). Specifically:

1. Modification documents did not detail all of the changes being made, nor were the bases for all of the changes included in the documents.

For example, some of the significant circuit modifications were not discussed in the modification documents and could only be identified by performing line-by-line comparison of the old and new elementary drawings. Examples include:

a. A change involving the control circuit being connected acmss the battery during cranking and

b. The failure to document adequately and assess the effects of the modification of switches on emergency diesel generator (EDG) 2 local shutdown panel.

These examples prevented the performance of a thomugh design review and safety evaluation, as well as development of an adequate test plan.

m __

< j v , j C321-95-2084  !

Attachment I l Page 2 of 4 i 1

2'. . The design contml measures did not adequately provide for verifying . I the adequacy of design. Specifically, the design verification for the l diesel generator governor upgrade, the diesel generator control  !

changes, and the upgrade modifications, were not adequate in that :

numemus design deficiencies existed in the original design and were not discovered by the design verifier. 'For example,- the design verifier did not identify the deficiencies set fonk above in Item A.I. In  ;

addition, the design verifier did not verify that there would be no L i impacts of the effects of electromagnetic interference on the EDGs  !

newly installed controls. Funher, a design verification was not j performed for the data acquisition system modification. j

3. Numerous field changes were not subject to design control measures .

commensurate with those applied to the original design, in that the design reviews were not performed for changes implemented by the  ;

field change program. For example, appropriate design verifications I were not performed for: Field Change (FCN) Clll332 which, in pan, l

added a governor shutdown solenoid; FCN Cl10721 which moved a 1 sensing line tap to correct a low water pressure trip; and FCN C110727 which added relay contacts to allow pmper operation of a voltage regulator and automatic synchronizer.

B. 10 CFR Pan 50, Appendix B, Criteria XI, Test Control, requires, in pan, that l a test program shall be established to assure that all testing requimd to {

demonstrate that structures, systems, and components will perform j satisfactorily in service is identified and performed in accordance with written i test procedures, which incorporate the requirements and acceptance limits j contained in the applicable design documents.

{

Contrary to the above, following modification of the EDGs between September - 'f and December 1994,  !

1. Testing required to demonstrate that the EDGs would perform satisfactorily in service was not adequately identified in the test plan to j

demonstrate the satisfactory operation of the EDGs. For example, the ~

test plan did not include all of the surveillance tests required to '!

demonstrate operability of the EDGs; the specified generic circuits )

continuity tests were not adequate to identify design and installation l deficiencies; the test plan did not delineate the caruits that were j required to energize, nor the circuit operability tests that were to be

.l performed; and the transient testing necessary to verify proper ,

operation of the new controls, was not identified. 1

- . s:

y r

C321-95-2084 1 Attachment I l Page 3 of 4 i

2. Testing requimd to demonstrate that the EDGs would perform <

satisfactorily in service was not performed and/or documented in f accordance with portions of the written test pmcedures. For example, all energized circuit operability tests performed in accordance with the j -

station generic test procedures, were not documented, and cimuits that '

j were tested during tmubleshooting efforts were not tested in accordance l with the written procedures nor were the results documented.

GPUN Realv i GPU Nuclear concurs with the pmblem. i i

Reason for the Pmblem l l

The problem was caused by ineffective project management. This resulted in j underestimation of project scope and resources required, missed project milestones,- l late material deliveries, the subsequent need to alter the original design, and the r resultant failure to revise the modification test plan. Additionally, there was- j incomplete documentation of modification design details. The mot cause for the l problem is attributed to over reliance on a single highly technically capable individual l

to perform multiple roles in the course of the project.

A contributing cause to the pmblem was ineffective management oversight evidenced by a decision to proceed with the modification based on motivation'to resolve long- j standing deficiencies without careful consideration of the impacts that the design changes would cause.

Conective Actions Taken and the Results Achieved All activities on Emergency Diesel Generator (EDG) #1 were suspended. A review team was fonned to assess the condition of EDG #1 and determine actions to address identified deficiencies as well as develop an action plan to prevent similar pmblems from occurring on EDG #2. Startup & Test activities were reviewed and revised to assure all elements of the modification were adequately tested. In addition, an independent assessment team was formed to evaluate the design process and its implementation for EDG #1, and an independent design verification for the modifications to both EDG #1 and EDG #2 was conducted. )

i i

i i

i C321-95-2084 l Attachment I j Page 4 of 4 j l

Corrrctive Steps Taken to Avoid Funher Problems Revisions to the modification process plan and implementing precedurea are scheduled ,

to be issued by the end of the first quaner 1995. These enha.ncements 8.nclude:

(1) establishing clear roles and responsibilities for all personnel performing activities i in the project management process; (2) establishing a certification program for project j managers; (3) establishing a mentoring pmgram for inexperienced project managers by partnering them with experienced personnel; and (4) establishing specific reviews by senior management for any projects that fail to meet established planning milestones. Training on these enhancements is scheduled to be completed by the end of the second quarter 1995.

A review of 15 modifications completed during the 15R outage showed that there wem no process problems of the type that occurred during the diesel generator modifications. Included in the review was an evaluation of the modification testing conducted and no similar problems to the DG testing discrepancies wem identified.

However, several changes were made to Stanup and Test procedures to enhance management expectations in this area. This review funher confirms the problems associated with the DG modification was an isolated event and that the corrective actions outlined above will prevent a recurmace.

Date When Full Compliance us Achieved Full compliance was achieved on November 25,1994 when the design verifications for the EDG modifications wem completed.

l l

l l

l l

~ -_ --_ .

1

!t O ., -

C321-95-2084 l

- Page 1 of 2 {

. i ATTACHMENT H i

Violation l 10 CFR 50.63, Ioss of all alternating current (AC) power, requires, in part, that each light-water-cooled nuclear power plant must be able to withstand for a specified l

duration, and recover from, a station blackout. The alternate AC power source will-  ;

constitute acceptable capability to withstand station blackout provided an analysis is- ,

performed that demonstrates that the plant has this capability from the onset of the  :

- station blackout until the alternate AC source and required shutdown equipment am '!

started and lined up to operate. .I

^

Contrary to the above, in May,1994, the control circuits of the alternate AC power sources (combustion turbines) were modified such that an acceptable capability did not-l exist to withstand station blackout. Specifically, a modification was made to the -  !

combustion turbines' control circuits which resulted in a turbine trip signal on the loss of power. As a result, between May and Novembcr 1994, the alternate AC power .

source combustion turbines could not be staited either locally or remotely from the  !

Control Room in the event of a station blackout and, consequently, the plant did not j have alternate AC power source needed to withstand station blackout during this .l period.  ;

i l

GPUN Reals: '

I GPU Nuclear concurs with the violation.

i

)

l Reason for the Violation  !

i The cause of the violation was a failure 'to establish agreements and controls between I GPUN and JCP&L to assure that modifications performed to the Forked River Combustion 'Iinbines (cts) would not affect their ability to function as intended for Station Blackout (SBO).

1

- ,.- - - - - ,-., y -,e3- + -.m.~

g -4 .a _ --

C321-95,2084 Attachment II Page 2 of 2 i

Corrective Actions Taken and the Results Achieved ,

i The cts gas leak detection circuit was modified and an uninterruptable power supply was installed on the circuit. Both CT #1 and CT #2 were successfully, functionally ,

tested by GPUN Startup & Test Department. ,

t i

Corrective Stens Taken to Avoid Further Violations Agreements were reached betweer GPUN and JCP&L to ensure: (1) the GPUN ,

System Engineer (SE) will be notilled of proposed design changes to the cts which potentially affect their operability; (2) the SE will provide concurrence for detailed design engineering for CT modifications which affect operability; (3) modifications which may affect the operability of the cts shall be post modification tested by JCP&L and the test procedure shall be reviewed by GPUN Startup and Test Department. SU&T will review the results of the testing or personally witne;s the testing and pmvide written concurrence that SBO capability is unaffected; and (4) the SE will also review the results of the testing or personally witness the testing and provide written concurrence the SBO capability is unaffected.

The interface with JCP&L has been improved and GPUN will on a periodic basis ,

continue to reinforce our agreements and understanding. i Ikte When Full Comnliance Was Achieved Full compliance was achieved on December 22,1994, when the functional testing for the modifications to both cts were completed. l l

l