ML20085N148
| ML20085N148 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 11/06/1991 |
| From: | J. J. Barton GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| C321-91-2302, NUDOCS 9111140147 | |
| Download: ML20085N148 (4) | |
Text
-______
\\
GPU Nuclear Corporation T U Nuclear
- en
- r38 Forked Rn,er New Jersey 08731-0388 609 971-4000 Writer's Direct D-al Number.
C321-91-230?
November ti,1991 U.S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D.C.
20555
Dear Sir:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 Inspection Report 91-25 Reply to a Notice of Violation In accordance with 10 CFR 2. 201, the enclosed provides GPU Nuclear's response to the violations identified in NRC's Inspection Report 50-219/91-25.
If further information is required, olease contact Brenda DeMerchant, OC Licensing Engineer at (609)971-4642.
Very truly j urs, J.J. Barton Vice President and Director Oyster Creek JJB/BDeM/jc cc:
Administrator, Region I Senior NRC Resident Inspector Oyster Creek NRC Project Mhnager
\\t 460 9111140147 Y1110e gos noocx osooo m O
PDh
[b
-12018L
C321 91 2302 y_tolation A:
10 CFR 50, Appendix B, Criterion VI, Document Control, requires that measures shall be established to control the issuance of documents, such as instructions, procedures, including changes thereto, which prescribe all activities affecting quality.
GPUN Operational Quality Assurance Plan Number 1000-PLN-7200.01, Rev. 5, Section 3.2,1 states that document control procedures shall be established to control the revision and change of approved-documents which prescribe methods or provide the technical requirements for activities and items within the scope of this plan.
Contrary to the above, measures established to control the issuance of changes to procedures were inadequate in that, on August 21, 1991, a temporary change to Station Procedure 636.4.003, Rev. 39, " Diesel Generator Load Test," was deleted from the procedure without any technical review, thus rendering the procedure ineffective.
The guidance provided in the temporary change was necessary for successful accomplishment of the test.
This is a severity level IV violation (Supplement 1).
Response
1.
GPUN agrees with the viola +. ion as stated. This violation was self identified.
2.
Reasons for the Violation:
The root cause of this occurrence is the procedural requirement to have a temporary procedure change " automatically expire" after a given time period, effectively changing the procedure without the proper reviews.
A contributing cause is the lack of a comprehensive temporary procedure cnange tracking system, beyond the current 14 day Technical Specification 6.8.3.c required approval period, to ensure the timely incorporation of temporary procedure changes into the next permanent revision.
L 3.
Corrective Steos Taken and Results Achieved:
L L
A temporary procedure change was prepared for Surveillance Procedure 636.4.003, " Diesel Generator Load Test" which incorporated the guidance previously deleted from the procedure.
Both emergency diesel generators were tested satisfactorily, using that procedure.
i Operations Support personnel have resumed the practice of notifying the originators of temporary procedure changes, approximately one week prior to its expiration, alerting the originator to re-issue the temporary change if it hasn't already been incorporated into the next revision of the procedure.
L L
(Attachment 1)
Page 2 3.
(Cont'd)
In addition, Procedure 107, " Procedure Control", was revised to lengthen the automatic expiration date from 60 to 90 days.
This was done in order to facilitate the transition of a procedure with a temporary change into a permanent, approved procedure.
4.
Corrective SteDs that will be taken to Avoid Further Violations m
In order to improve the method of tracking temporary procedure changes, the Safety Review Manager will implement a change to the computer data base currently in use.
Plans are to expand the data base such that temporary changes may be tracked beyond the 14 days required by Technical Specification 6.8.3.c for implementing approval. This will enable the Safety Review Manager to identify temporary procedure change approaching their 90 day expiration date, and either expedite the revision process or ensure the temporary change is re-issued.
Also, Procedure 107 " Procedure Control" will be further revised such that temporary procedure changes intended for permanent incorporation into the precedure will not be deleted upon expiration.
- Rather, these temporary changes will be required to be incorporated into the next revision of the procedure, or re-issued with the proper reviews, prior to the end of the 90 day period.
5.
Date When Full Comoliance Will be Achieved full compliance was achieved on August 26, 1991, when a temporary procedure change was made to Procedure 636.4.003, " Diesel Generator Load Test". This temporary change was incorporated into Revision 41 of the procedure, which became effective October 6, 1991.
Violation 8:
Technical Specification 3.12.C.1 requires that fire protection spray and/or sprinkler systems listed in Table 3.12.2 be operable. Table 3.12.2 specifies operability of deluge system 5 for the reactor building 51 ft, elevation - north (fire area RB-FZ-lD).
Technical Specification 3.12.C.2 repires that when one or more of the above required spray and/or sprinkler systems is inoperable, a continuous fire watch is to be established, with backup fire suppression equipment for those areas in which redundant systems or components could be damaged.
Contrary to the above, from August 3, 1991 until August 5, 1991, fire suppression deluge system 5 was inoperable in the reactor building 51 ft.
elevation - north, which is an area containing redundant components, and a continuous fire watch was not established.
This is a severity level IV violation (Supplement 1).
C321-91-2302 (Attachment 1)
- ., 3 Rage 3 Violation B (Cont'd)
Response
1.
GPUN agrees with the violation as stated. This violation was self-identified.
2.
Reasons for the Violation As identified in the Operations Critique Report written for this event, the root cause of this occurrence was determined to be inadequate procedural guidance in that the applicable Response to Alarm Procedures do not differentiate between " trouble alarms" that may indicate an inoperabla automatic suppression system and those that do not.
3.
[orrective Steos Taken and Results Achieved:
Immediate corrective action was taken, including the posting of a continuous firewatch and specific direction provided by the Manager, Plant Operations to all Group Shift Supervisors regarding fire suppression system operability. This direction dictates that a fire suppression system should be considered inoperable, upon receipt of an area trouble alarm, until the system can otherwise be proven operable.
Initially, in such instances, a continuous firewatch will be posted, which is conservative with regards to Technical Specification. requirements.
Subsequent interim corrective action resulted in the development of an Operator Aid, which was posted at each local fire alarm panel to provide guidance for responding to alarms specific to that panel.
- The Operator Aid specifies the action to be taken for each alarm indication received, in terms of fire suppression system operability and type of firewatch required to be posted.
4.
Corrective Steos That Will be Taken to Avoid Further Violations:
Permanent corrective actions will be accomplished when the Response to Alarm Procedures are revised to incorporate the specific corrective actions required whenever a main or local fire alarm panel annunciates.
5.
Date When Full Como11ance Will be Achieved:
Full compliance was achieved on August 5, 1991, when a continuous firewatch was established at 3:45 p.m. for the Reactor Building - 51' elevation.
-