ML20101F141
| ML20101F141 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 06/15/1992 |
| From: | J. J. Barton GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| C321-92-2171, NUDOCS 9206240295 | |
| Download: ML20101F141 (4) | |
Text
o OPU Nuclear Corporation G
U iuclear
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Forked River, New Jersey 08731-0388 609 971 4000 Writer's Dir0Ct Dial Number:
1 June 15, 1992 C321-92 2171 h
U.S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, DC 20555 Deer Sir:
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.
If you should have any questions or require further information, please contact Brenda DeMerchant, OC Licensing Engineer at (609) 971-4642.
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John J. Ba t n Vi e Presi t & Director 0 ter Cree-4 JJB/BDEM:jc Enclosure cc:
Administrator, Region 1 Senior NRC Resident inspector Oyster Creek NRC Project Manager
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GPU Nuclear Corporaten is a subsdary of Genera Pa,: Uwes co<pora' an
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C321s92-2171 Page 2 Violation Section 50.47(b)(8) of 10 CFR Part 50, requires the licensee to have adequate emergency response facilities and equipment to support the emergency response provided and maintained. A June 12, 1984, Confirmatory Order requires the licensee to comply with the commitments as stated in the April 15 and July 19, j
1983, and the March 9, and April 9, 1984 correspondence in response to commitments on emergency response capability schedules.
The habitability of the Technical Support Center (TSC) was described as meeting the requirements of Standard Review Plan (SPR) 6.4, " Control Room Habitability System" as they pertain to Control Rooms, with the exception of automatic actuation, seismic and redundancy criteria.
SRP 6.4, Section 6.4-11.3, specifies that the ventilation shall be tested on an 18 month frequency.
1 Specifically, the TSC ventilation system was to be tested to verify that system makeup was 10*/,of the design value, and that the TSC can be pressurized to at least 1/8 inch water gage while making up at the designed rate.
I Contrary to the above requirements to maintain and test the TSC ventilation
- system, adequate maintenance and testing was not conducted since completion of construction of the TSC in 1985 until December 1991.
This was evident by the degraded condition of the TSC ventilation system discovered during testing in November and December, 1991.
This is a Severity Level IV violation (Supplement Vill).
flesponse:
GPUN concurs with the violation as stated.
- 1) Reason for the Violation:
l As discussed during the enforcement conference on April 30, 1992, although we i
were aware that a Confirmatory Order had been issued, we believe the root cause of this violation was that specific requirements as to the maintenance, testing, and surveillance of the TSC ventilation system were not clearly defined in the project documentation.
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C321-92-2171 Page 3 i
BHPoise Cont'd The following contributing factors also led to the violation :
The incomplete work list overdue commitment dates did not receive appropriate attention, even though they are reviewed periodically.
The Site Emergency Building (SEB) was a major project with low visibility relative to plant activities since it had a minimal interface with plant systems.
The TSC ventilation system was overshadowed by the large amount of SEB construction deficiencies unrelated to the TSC.
j An SDD Division 2, which provides information for operations and maintenence of the system, was not developed for this project.
2)
The following corrective ~ ions were immediately initiated upon discovery of the degraded condition of the TSC ventilation system :
A review of TSC operability determined that the facility would remain operable assuming the degraded ventilation system perfo rmance.
An automatic, alarming lod ba sampler was placed in the ISC.
The device would alarm at a prese'. lodine concentration.
Respirator qualifications were checked and were current for all required TSC duty roster positions.
(Position numbers 200-249).
Respirator qualifications were checked for all supplemental ISC positions, (Position Numbers 250-299) and although respirator qualifications are not required for these positions, personnel are encouraged to maintain qualifications.
The onsite supply of respirators and charcoal impregnated filters were reviewed and found to be adequate te support emergency operations.
Other Confirmatory Orders regarding NUREG 0737 were reviewed to assure similar compliance issues did not exist at the station.
All outstanding Incomplete Work List (lWL's) items were reviewed to assure similar items did not exit.
An outside contractor was retained to perform the required testing.
C321-92 2171 Page 4 3)
Corrective steps to be taken to avoid further violations :
Since the TSC was designed and constructed in the early 1980's improvements to the design review process have evolved.
These include:
The preparation of in depth System Design Description documents (divisions 1 & 2 ) which define in detail the design criteria and maintenance / surveillance requirements are now required.
The requirement for project review meetings, in the form of preliminary engineering design review (pEOR), and operability, maintainability, constructability review (OMCR),
reinforces the establishment and understanding of maintenance and surveillance 1
requirements.
These improved processes have been in offect since approximately 1986.
In addition to the above, a formal " turnover" meeting for the Technical Support Center portion of the Site Emerge; icy Building will be scheduled during the third quarter of 1992. This meeting will establish the " ownership" of the TSC and which department is responsible for each aspect of the facility operation and maintenance.
4)
Date of full compliance:
Full umpliance was acheived on March 31,1992, when Nuclear Consulting Services successfully performed the required testing on the TSC ventilation system.
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