ML20100B745
| ML20100B745 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 03/15/1985 |
| From: | Fiedler P GENERAL PUBLIC UTILITIES CORP. |
| To: | Kister H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8503280548 | |
| Download: ML20100B745 (7) | |
Text
.
GPU Nuclear Corporation Nuclear
- is=:r888 Forked River.New Jersey 08731-o388 609 971-4000 Writers Direct Dial Number:
March 15, 1985 l
Mr. Harry B. Kister, Chief Division of Project and Resident Programs U.S. Nuclear Regualtory Commission Region I 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Kister:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-P.19 Inspection 84-28 to this letter provides our response to the Notice of Violation contained in Appendix A of your letter dated February 15, 1984.
In addition, Attachment 2 contains the requested supplementary infonnation on our commitment tracking system.
If there are any questions, please contact Mr. Michael Laggart of ray staff at (201) 299-2341.
Very truly yours, jL Y et edler Vice President and Director t
Oyster Creek PBF/kb/rj
- 0919A Attachments cc: Dr. Thomas E. Murley, Administrator Region I U.S. Nuclear Regulatory Commission 631 Park Avenue 8503280548 8503 g King of Prussia, PA 19406 PDR ADOCK 0500 G
NRC Resident Inspector Oyster Creek Nuclear Generating Station Forked River, NJ 08731 J a 6/ y 7
GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation
ATTACHMENT 1
. Violation Technical Specification 6.8.1 requires that written procedures shall be established, implemented, end maintained.
Oyster Creek Station Procedure 105, Conduct of Maintenance, which provides the standard administrative, management and radiological control practices for the planning and conduct of maintenance at Oyster Creek, Section 6.4
_ describes the job order section of the Maintenance and Construction Short Form as identifying the maintenance work requirements and special instructions.
-Maintenance and Construction Short Form 02877, dated September 27, 1984, written to verify the proper installation of the Emergency Service Water Pressure Gauges on top of the Containment Spray Heat Exchangers in the Job-Order Section stated, in part, " Insure isolation root valves are left open and gauges operable."
' Contrary to the above, following the gauge replacement, the Emergency Service Water Pressure Gauges were not operable in that-the gauge root valves V-3-527, V-3-528, V-3-520, and V-3-521 were left closed.
This is a Severity Level V violation (Supplement I).
Response
GPUN recognizes that the subject instrument valves were out of position as described and as such, constitutes a lapse in valve lineup procedure control. The job order section of the subject Short Form did comply witn the requirements of Procedure No.105, and adequately described the job to be_ perfonned.
Instructions to open the root valves were included in the Job Order Section.
It should also be noted that the Action Taken/ Remarks Section of the back page of the applicable Short Fonn states that proper gage installation, calibration and root value alignment to the "open" position had been verified.
This was confirmed through actual discussions with the job supervi sor. An in-service leak test was performed on 10-13-84 for which j
the root valves were open and QA verification of the test was obtained Based on infonnation presently available it cannot be determined when or by whom the valves were closed other than during the performance'of M4C Work.
As a result of this incident, all M&C production personnel have been instructed not to alter any valve positions unless they are within the -
tagged out boundary or it is covered by instructions in the Short Form or procedure. Plant Operations has stressed the reouf rement to assure proper system lineups subsequent to modifications or maintenance.
1 i
L_
.~
i t
1 of 5 l
ATTACHMENT 2 Your letter of February 15, 1985 requested supplementary infomation
^
I regarding our commitment tracking system and referenced pages 4 through 6 of the inspection report. The report identifies and describes in detail two concerns. Each of the items will be addressed separately; however, the cover letter of your inspection report indicates that supplemental infonnation regarding our tracking system will alleviate these concerns. We do not believe that reliance on the tracking system for total control of commitments is appropriate.
The connitment tracking system, which is implemented by procedure LP-002 " Regulatory Correspondence Management and Commitment Control", is viewed by GPUN as a management tool. Tne " purpose and scope" of the procedure states:
"This procedure defines and establishes the GPUN system for the management of incoming and outgoing regulatory correspondence and the assignment of tasks 'ssociated with that correspondence.
Control and documentation of cr citments made to regulatory agencies in outgoing correspondence is provided via a task management reporting system.
The procedure pertains to intradivisional contributions to responses made to regulatory agencies."
The tracking system identifies and lists commitments, and provides summary reports to personnel responsible for implementation and to their respective i
management.
It is not, however, a control system which ensures the action will be completed. As would be expected, appropriate management action, based on infonnation supplied through the tracking system report, is necessary j
for completion of a connitment.
We are aware that the tracking system has been referred to as a corrective action in previous correspondence and it has proven to be an effective management infonnation system.
It was not intended, however, that the system be regarded as the sole controlling mechanism to ensure compliance. We regret any misunderstanding that may have occurred.
f The first concern identified in the inspection report was stated as follows:
(0 pen) Violation 83-26-01: Fire pump surveillance procedure failed to incorporate a new surveillance required by a Technical Specification (TS)-
i change.
The licensee, by letter, P. B. Fiedler to R. W. Starostecki, dated Marcn 28, 1984, described the corrective actions which had been taken to assure that Technical Specification changes are incorprated into facility procedures. Among the corrective actions taken were a revision to the fire pump surveillance procedure incorporating the TS change and a review of all surveillance procedures to ensure that the procedures reflect TS requirements. This action was verified to have been performed. Also, the fonnalized process by which TS changes are now incorporated into facility procedures was described.
Tnis process consists of controlling the distribution of TS changes through a Licensing Action Item System.
By this system, the licensing organization generates Action Items that are routed to Plant Engineering for verification that all procedures, affected by each amendment, are reviewed and changed as necessary.
I
. ~.
X 2 of 5 The effectiveness of this system was reviewed during this inspection.
The licensee's Procedure LP-002, Regulatory Correspondence _ Management and Commitment Control, establishes the system for the assignment of tasks l
associated with regulatory correspondence. The procedure requires the
~
Unit Licensing Supervisor to assign action, as appropriate, using the Action Item Form. This form describes the action to be taken and also establishes a due date for completion of the action.. The procedure also i
states in paragraph 4.1.6, "If the Section Manager assigned to the Action Item is unable to complete the task by the assigned date, he shall notify
[
licensing immediately."
h The licensee's actions taken to ensure facility procedures are reviewed and revised,"to include changes resulting from three recently issued License Amendments (Amendments 71, 72 and 73) were reviewed. Results of this review show that for each amendment a Licensing Action Item was prepared and assigned to Plant Engineering for completion.
The Action Items basically required procedure reviews to ensure the requirements of the amendments are incorporated in the appropriate procedures. Also, the Action Items established assignment due dates.
None of the Action Items had been completed at the time of the inspection. The Action Item associated with Amendment 73 was being processed in accordance with Procedure LP-002 in that an extension for the due date nad been requested. The Action Items associated with Amendments 71 and 72 were i
not processed entirely in accordance with Procedure LP-002, in that due dates were not adhered to, nor were extensions requested in a timely manner. The-dates associated with these amendments are as follows:
F Amendment 71 Action Item # 83178.02 assigned to Plant Engineering on 2/6/84.
Action Due Date: 3/6/84 Plant Engineering requested an extension to 8/17/84 on 7/2/84.
Action Item overdue in that on 9/7/84 it had not been completed.
3 Amendment 72 Action Item # 83071.02 assigned to P1 ant Engineering on 2/16/84.
Action Due Date: 4/27/84 Plant Engineering requested an extension to 8/15/84 on 6/25/84.
Action Item overdue in that on 9/7/84 it had not been completed.
i The inspector noted in addition to the above, a significant number of other assigned Action Items have not been completed nor have they requested an extension to the due date. This is true despite the fact that licensing, two weeks prior to a due date, notifies departments having Action Items assigned of the impending due date.
The. failure to process Action Items in accordance with LP-002 was discussed in detail with the Itcensee during the inspection and again during a telephone conversation on September 20, 1984.
The licensee noted the delay in completing the Action Items was partially due to the heavy workload during the extended outage, that no violations of TS had
=-
3 of 5 occurred, and that the restart certification program, as well as Procedure LP-006, " Plant Technical Specification / Operating License Change Control" would ensure that all requirements of these and other assigned Action Items would be completed prior to their need for plant operation.The licensee further stated that he was not satisfied with the implementation of the corrective action specified in his response to Violation 83-26-01 and that a supplementary response would be provided to amplify the original response.
The objective of procedure LP-002 is to identify and track commitments to help ensure compliance with applicable regulations. We agree that verbatim compliance to LP-002 did not occur in that Plant Engineering did not fonnally request an extension to the Licensing Action Items (LAI). Had they requested such an extension, it would have been granted because the Amendments in question were not applicable during the cold shutdown condition (0yster Creek at that time was in an extended refueling outage).
An element of judgement is. involved in the extension of an LAI due date whether or not it is documented in writing, therefore the failure to document such an extension has no more and no less effect on plant safety than when the extension is documented in writing.
It should be noted that the Licensing Manager as well as the responsible implementing manager receives and reviews-the listing of overdue items, and could take appropriate action to ensure that an LAI is completed expeditiously if, in his opinion, plant safety or regulatory compliance is at issue. This management overview is essential in ensuring that control is adequately addressed.
In this case both Plant Engineering and the Licensing Department realized that the required procedures addressing the subject Technical Specification Amendments would not be needed until plant restart.
As stated previously, procedure LP-002 is a management tool.
In this instance, in addition to the tracking system, other management control mechanisms were in place to ensure procedure development was effected prior to restart.
The " restart certification program" carried this as an item for completion prior to restart and procedure LP-006, " Plant Technical Specification /0perating License Change Control", which makes all affected departments aware of the amendment's requirements, had been implemented.
The objective of procedure LP-002, that is to identify and track, was accomplished. Necessary procedures were in fact established prior to restart and there were no Technical Specification violations. Although our goal is to achieve verbatim compliance with procedure LP-002, we do not believe it appropriate that the NRC require verbatim compliance for those procedures in excess of those identified in our Operating License and Technical Specifications.
4 of 5 The Oyster Creek Operating License and Technical Specifications, section 6.8.1 of Appendix A states:
" Written procedures shall be established, implemented, and maintained that meet or exceed the requirements of the Nuclear Regulatory Commission's Regulatory Guide 1.33 (the applicable revision is identified in the GPU Nuclear Operational Quality Assurance Plan) and as provided in 6.8.2 and 6.8.3 below. "
l GPUN maintains that procedure LP-002 does not fall within this category and as such, should not be auditable by NRC within the context of plant safety; and that in issuing periodic listings on the status of commitments to assigned individuals and respective management, GPUN meets the intent of our NRC commitment to maintain a tracking system.
The second concern relating to the comitment tracking system, was stated as follows:
(0 pen) Violation 81-05-02: Failure to conduct procedure reviews as required by Technical Specifications. The licensee by letter, P. R.
Clark to T. T. Martin, dated June 24, 1981, described the corrective actions which would be taken to avoid further violations. These corrective actions basically consisted of a commitment to revise Procedure 107, " Procedure Control", to require a more effective means of documentatien of periodic procedure reviews and that all procedure reviews will be documented per the revised system. The letter further stated full compliance will be achieved by December 31, 1981.
In addition, in the same letter the licensee described a commitment control system which was established to ensure that commitments made are adequately addressed. During the review of the licensee's corrective i
action it. ras noted the licensee's commitment, to be in full compliance by December-31, 1981, was not met. An attachment to Task Status Report for Task 81026.12, which was prepared to accomplish the actions necessary to fulfill the comitment, documented that the revision to Procedure 107 was not submitted until June 8,1982 and that the December 31, 1981 deadline was not met.
The significance of failing to meet a commitment made to the NRC in l
response to a Notice of Violation was discussed with licensee i
representatives on site and again, in detail, during a phone conversation with the Director of Licensing on October 11, 1984. During the phone conversation, the NRC requested the licensee provide written comments on this matter and proposed corrective actions to ensure the maintenance of an effective tracking system. 'This written response will also incorporate the supplementary response to violation 83-16-01 discussed above.
The tracking system is used to identify those commitments which will not meet previously committed to dates.
It has been the practice in the past to comunciate to NRC when committed dates will not be met and the reasons for the delay. This comunication took the form of either a docketed letter or
n 5 of 5 was accomplished verbally, most often with the resident inspector.
In the past, verbal communications were not always documented. Based on standard practice at the time (1981-1982 time frame), we believe the delay in completing this commitment was communicated verbally, however, it was not documented. This past practice was communicated to the inspector.
In addition, we pointed out that additional examples of a slipped commitment date with no formal documentation of NRC notification, could probably be found in the files, however, this did not necessarily imply notification was not made.
In order to avoid future concerns in this area, verbal notifications of extended commitment dates will be documented and placed in the appropriate file.
It should be pointed out, however, that the tracking system identified and highlighted this item as being overdue and tracked it to eventual completion.
As a mangement tool it accomplished its objective.
_