ML20093L966
| ML20093L966 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 05/11/1984 |
| From: | Wilson R GENERAL PUBLIC UTILITIES CORP. |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20093L888 | List: |
| References | |
| RFW-0122, RFW-122, NUDOCS 8410190305 | |
| Download: ML20093L966 (4) | |
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ATTACHMENT I OPU Nuclear Corporation
@lg7 100Interpace Parkway Parsippany, New Jersey 07054114 (201)263-6500 TELEF.136 482 Writer's Direct Dial Number:.
May ll, 1984 RFW-0122 Dr. Thomas E. Murley, Administrator Region 1 U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406
Dear Dr. Murley:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 IE Inspection 84-09 During early April, an NRC Inspection Team headed by Mr. L. Tripp, reviewed a number of items at the Oyster Creek Station including the general subject of design and modification control for plant changes made during the current outage. The specific inspection report has not, as of this date, been received by GPUN, however, certain commitments were made at the time of the s
audit exit meeting by the undersigned and additional commitments were subse-quantly made in a phone call from Mr. Keimig, Region 1, to Mr. P. R. Clark, GPUNC. The purpose of this letter is to update you regarding the status of these commitments.
At the time of the exit interview, the undersigned agreed to conduct a i
general technical review of all field change requests (FCR's) required for the modifications to the Scram Discharge Volume System. This review was requested by the NRC Audit Staff based upon the large number of FCR's for this modification. Although each FCR was independently reviewed, residual l
. concerns existed about whether the large number, taken as a whole, impacted the functional design requirements of the system. Such a review has been performed by the modification designer, Stone & Webster, and the iesults transniitted to GPUN. We are making the Stone & Webster report available to i
the Oyster Creek NRC Resident Inspector.
The Stone & Webster review con-cludes that the scram discharge modification (i.e., all FCR's) meets the l
intent of the original performance and design requirements.
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8410190305 841012 PDR ADOCK 05000219 G
PDR GPU Nuclear Corporation is a subsidiary of General Public utilities Corporation
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Dr. Thomas E. Murley May 11, 1984
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Page Two
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-As part of a continuing GPUN effort to look at design control, and expand upon 1
the NRC inspection, the NRC requested that we internally audit an enlarged number of modifications being. performed at Oyster Creek. The audit was initiated:in early April of this year, and the audit report was received on May 7, 1984.- (This audit report is also being made available to the Oyster l
Creek NRC Resident Inspector.) The audit examined 12 total modifications and represents a spectrum of different design organizations, internal project A
engineers, and time frames in which the design was conducted. The report
.contains no specific findings and generally concludes that the modification projects examined are technically consistent with the baseline engineering documents and requirements. The audit report, however, identifies a number of administrative problems, some lack of specific procedural guidance, and incon-3 sistencies in some project engineering judgements. These areas could have the potential for. future difficulties and do impact our internal productivity and i-
' documentation processes. 'The balance of this letter discusses and addresses our initial assessment and response to these audit recomendations.
The audit report identifies the fact that changes have been made to original t-design agent documents, as a result of FCR's, by GPUN without recourse to the original designer. This practice is permitted by GPUN procedures where the required action definition can clearly be evaluated by GPUN. For complex changes, or changes requiring detailed knowledge of the original design calcu-lations, our policy requires review by the original designer. The audit noted a large number of field changes handled by GPUN in this manner and that change documents, once made, were not always distributed back to the original design s
agent. We believe that the policy of allowing minor changes to be made internally is proper, but find that the number being handled by the internal GPUN project engineer is inconsistent with other duties and responsibilities and that-a greater fraction of FCR's should have been referred back to the l-original designer. We are taking steps to improve the procedural and policy guidance to the engineering staff to require preferential handling by the original design agent..Further steps are being taken to ensure that all change documents and revisions will be routinely distributed to the designer.
A second observation of the GPUN audit is that the number of field change docu-I ments should be reduced throt";h increased field walkdowns and constructability l
reviews prior to completion of the engineering package. We have stressed this l
.with the engineering staff for the last year and a half and believe that most
'of the problems identified in the audit stem frem previous engineering prac-tices or failure, in selective cases, to adhere to current direction. Our internal guidance calls for a walkdown of all jobs both before the start of l-engineering and during the engineering process; and for preliminary engineer-ing and final engineering constructability reviews. We are reinforcing this L
direction to the internal engineering staff as well as to our engineering
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r Dr. Thomas E. Murley May ll, 1984 Page Three contractors,- and are putting in place administrative checks at the site to be sble to monitor such activities. We have considered this practice essential to. assure the adequacy of initial engineering efforts and are continuing to stress the. implementation of job walkdowns.
i A third general. recommendation of the audit is the reinforcement on ensuring all documentation is transmitted to and through our Engineering Documentation and Control' Center (which provides a computerized document data bate) and j
ensuring that Architect / Engineer's or other design agents have either computer l
access or some other reliable access to that data base. We are continuing to
- emphasize, and our procedures require, release of all engineering documents through the Engineering Documentation and Control Center. We believe most of the identified problems in the audit stem from work performed prior to or in the early formulative stages of GPUN, i.e., under the direction of previous JCP&L Generation Division.
In addition, some audit observations may reflect some misunderstandings on the part of the audit team.
Nevertheless, we are reviewing each of the documentation problems identified in the audit to see if l'
generic' problems exist with the current control process. We had previously-l notified our major engineering contractors in a letter dated October 4, 1983, l-that we wish them to acquire computer facilities to tie in to our central data j
files. Two major contractors have acquired such terminals and will be L
connected in one to two months. Additional engineering contractors are still internally reviewing this action. We plan to reiterate to our contractors the l-need for such access.
The fourth area identified by the audit, as well as by previous internal i-reviews, is that fact that a large number of change documents can be out-standing against a drawing or specification. While this permits design modification control, if the numbers become too large it becomes unwieldy and
' time consuming for field construction and quality control. We are moving to change our procedures to ensure systematic release of original engineering as well as to limit the number of change documents outstanding against any one type of engineering document. This will still permit the needed flexibility in the system, yet restrict numbers of change documents prior to requiring a revision.
The audit also comented upon the completeness of design modification packages at the completion of work. We are reviewing our current practices but believe that existing procedures which require the development of such modification L
packages (on.the~CARIRS data base) is proper and the preferred approach for
' permanent record retention. We are, however, examining procedures in detail to see if minor modifications are warranted. The inconsistencies identified
.in the audit are being reviewed but most are thought to result from earlier projects performed to procedures in place prior to the implementation of the current GPUN design control process.
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._am Dr. Thomas E. Murley
-May_11, 1984 Page Four Specific ongoing reviews are also being conducted relating to specific technical observations raised in the audit; the reconenendation to review in detail two additional projects, i.e., Budget Activity 402052, " Containment
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Pressure, Water Level and Hydrogen Monitor Systems," and Budget Activity
'402024. " Appendix J Containment Leak Rate Modifications;" and observations
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relating to regulatory notifications.
I would be happy to meet with you to discuss the attachments or planned internal policy changes should you so desire.
-V truly yours, i
f R1 F. Wil on Vice President Technical Functions
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RFW/al
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cc: P. R. Clark P. B. Fiedler R. L. Long F. F. Manganaro NRC Resident Inspector, Oyster Creek Nuclear Generating Station, Forked River, New Jersey 08731 l
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