ML20096F636

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Responds to Violations Noted in Insp Rept 50-219/92-04. Corrective Actions:Temporary Change Issued on 920306 W/ Corrected Number & Description of Breakers & Change Included in Rev 46 to Procedure 308
ML20096F636
Person / Time
Site: Oyster Creek
Issue date: 05/18/1992
From: J. J. Barton
GENERAL PUBLIC UTILITIES CORP.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
C321-92-2150, NUDOCS 9205210265
Download: ML20096F636 (3)


Text

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i GPU Nuclear Corporation

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forked River, New Jersey 087310388 609 971-4000 Writer's Direct Dial Number; C321-92-2150 May 18, ;992

U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Dear Sir:

l

Subject:

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

Inspection Report 92-04 L

Reply to a Notice of Violation In accordance with 10 CFR 2.'201, the enclosed provides GPU Nuclear's response to the-Notice of Violation identified in NRC's Inspection Report 50-219/92-04.

Should you have any questions, please contact Brenda DeMerchant, Oyster Creek Licensing Engineer at 609-971-4642.

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ice Pres'de and Director Oyster Cr-JJB/BDEM:jc cc:

Administrator, Region 1 Senior NRC Resident Inspector Oyster Creek NRC. Project Manager 210049 9205210265 920S10 PDR ADOCK 0500 9

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GPU Nuclear Cc poration is a subsidiary of General Pub!ic Ututies Corpo ation -

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Enclosere' C321-92-2150 Page 1 of-2

- Viol ation:

Technical Specification 6.8.1 requires that written procedures shall be established,- implementeo, and maintained that meet or exceed the recommendations of Ragulatory Guide (Reg Guide) 1.33, revision 2, Quality Assurance Program Requirements (Operation). Reg Guide 1.33, Appendix A, recommends that procedares should be provided for the operation of safety related systems, it.luding emergency core cooling systems, and for the control of equipment.

Station procedure 308, revision 45, " Emergency Core Cooling System Operation,"

section 4.3 (Placing the Emergency Core Cooling System in Standby Readiness) requires the completion of valve and electrical checkoff lists 308.1 and 308.2 to plac. the emergency core cooling system in standby readiness.

Statior >rocedure 108, revision 53, " Equipment Control," paragraph 4.10.8 require. that during the conduct of equipment positioning and verificat;ons, each component shall be checked to ensure that a correct component label is present, and that labeling deficiencies shall be reported to the GSS for disposition.

Contrary to the above, on May 2,1991, written procedures were not adequately established and implemented as evidenced by the following examples:

1.

Procedures were not adequately established in that electrical checkoff list 308-2 was not complete as required when it was discovered on March 5, 1992, that two breakers required to be verified by the checkoff list were not included on the list.

Breaker #15 on 125 VDC Panel F,-panel 18R/19R alternate power source for reactor water level low-low signal, was not included on checkoff list 308-2 as required to ver fy core spray standby readiness. The power supply for Panel 2F Solenoid Valves, breaker #19 on panel:VACP-1, had not been verified by any previously completed electrical checkoff list.

2.

Procedures were not adequately-implemented in that operators did not identify and report the breaker labeling and checkoff list 308-2 description differences to the GSS for disposition as required by station L

procedure 108, step 4.10.8, during the equipment verification conducted on L

May 2, 1991.

This is a severity level IV violation (Supplement I).

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Enclosure-C321-92-2150-Page 2 of.2 Rgsoonse:

GPUN concurs with the violation as stated.

The reason for the violation is clarified as -follows:

The' Electrical Checkoff List for Procedure 308, Emergency Core Cooling system, did not correctly identify.two breakers required to be energized, prior to placing the system in standby readiness.

One Breaker (#15) was correctly described but incorrectly numbered. The description of the other breaker (#19),

l contained outdtted information and referenced the wrong panel and breaker number.

L Although breaker schedules posted inside electrical panels are not controlled j

procedurally, neither - description - matched the respective breaker schedule l

description and, when the Checkoff was completed, these discrepar.cies were not l

noted.

L Corrective Actions Taken and Results Achieved:

Temporary change T/C 3/6/92-9 was issued on March 6 1992 with the corrected-number and description of the breakers.

The temporary change has since been -

included in revision 46 to Procedur e 308.. Additionally, the Electrical Checkoff Lists for other. safety relatad systems were walked down, resulting in the issuance of three additional temporary procedt/e changes. Deviation reports were written for all discrepancies found.

Corrective Action To Be Takeni The corrective Lactions specified above should prevent the recurrence of such t

procedural discrepancies. The modification process, as described in Procedure p

124, " Plant Modification Control" will capture any future changes to electrical panels and ensure all procedure revisions are-complete.

In addition, an effort is underway to review and upgrade all breaker schedules to Operator Aid status.

An Operator Aid can consist of a graph, chart,-instruction, drawing or other l

document that may be used-by per ann 91 to assist them in operating the plant.

l These Operator Aids are procedurally controlled.

l Date When Full Comollance Will Be Achieved:

l Full compliance was achieved on March 6,1992 when Temporary Procedure Change T/C L

3/6/92-9 wa.s issued.

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