ML20104B985
| ML20104B985 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 09/10/1992 |
| From: | J. J. Barton GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| C321-92-2250, NUDOCS 9209170035 | |
| Download: ML20104B985 (4) | |
Text
-.
'd GPU Nu<. lear Corporation G. !J Muclear-
- ,,o;;;38" Forked River, New Jersey 08731-0388 609 971 4000 Writer's Direct Dial Number.
C321-P2-2250 September 10, 1992 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C.
20555 4
Gentlemen:
Subject:
Oyster Creek Nucle eenerating Station o
Docket No.50-21C Inspection Report 9?-14 Reply to a Notice ef Violation i
ll In accordance with 10 CFR 2.201, ',9e enclosed provides GPU Nuclear's response to the Notice of Violation ident't)'d in NRC's inspection Report 50-219/92-14.
Should you have any questions, please contact Brenda DeMerchant, Oyster Creek
(.icensing Engineer at 609 971-4642.
Very trul ourso
/
Jihn J. B
.on ce Presi
'n' & Director yster Cre k JJB/BDEM:BDe cc:
Administrator, Region 1 Senior NRC Resident Inspector
'0yster Creek NRC Project Manager i
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92C9170035 920910 PDR ADOCK 0S000219 f.
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GPU Nuclear Corporadon is a subsidwy of Genera! Pubhc UuhDes Comordbon
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Enclosure C321-92 2250 Page 1 of 3 y_iolation:
- Technical. Specification 6.8.1 requires that written proced>?res shall be established, implemented.and maintained that meet or exceed the requirements of Regulatory Ouide (Reg Guide) 1.33, revision 2, " Quality Assurance Program Requirements'.(Operation)".
Reg Guide 1.33, Appendix A requires-that procee es be written.for survri; lance testing of the containment spray system.
- Station procedure 602.3.014, revision 0, "Electromatic Relief Valve (EnRV)
Pressure Sensor / Pilot Valve Control Relay - Test and Calibration," uep 6.3,
_ provides guidarice as to the location of the 'B' EMRV pressure senscr.
Contrary to_--the above, on Ju.y 5, 1992, two instrumentation and controls
-technicians failed to properly implement procedure 602.3.014 in that a test of the
'C' EMRV pressure sensor was performed with the 'B' EMRV pressure sensor taken out of service for testing. - As a result of this action _the
'C' EMRV was inadvertently l
op ned for a pericd of about 8 seconds.
Thi.s is_ a-Severity Level IV violation (Supplement I).
- (Violation s'.ould have stated Safety Valve Tests rather than Containment Spray
' System).
Response
GPUN concurs with the violation as clarified.
The' reasons for the' violation are as follows:
During the 1600 to 2400 shift on July 5, 1992, two instrument and control technicians were scheduled to perform the EMRV pressure switch test and calibration. surveillance.
After a review of the surveillance, the Group Shift Supervisor (GSS) gave the I&C technicians permission to perform the surveillance at 1730 hours0.02 days <br />0.481 hours <br />0.00286 weeks <br />6.58265e-4 months <br />.
The I&C technicians went to ir;trument rack RK01, which is located on the 67' platform elevation, accessed-from the reactor building 75' elevation.
After requesting the control room operators place the control switch for' the 'A' EMP.V in'the off position, they performed a calibraticn on the pressure switch for ztheA' EMRV. Control room operator then placed the contrnl switch for the 'A' EMRV in automatic, i
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Enclosure C321-92-2250 Page 2 of-3 While still.at instrument rack RK01, tht I&C technicians requested that the control switch for the 'B' EMRV be placed in the off position per step 6.3.1 of
_the surveillance in order to test the pressure switch for he 'B' EMRV.
This instrument is located on the reactor building SI' elevation (west) and is so stated in section 6.3 of the procedure. However, the I&C technicians instead went to the pressure switch for_the 'C' EMRV on instrument rack RK02, which is located on the reactor building 51' elevation (east) and proceeded to perform a calibration of the pressure switch for the 'C' EMRV instead of the pressure switch for the 'B' EMRV.
Prior to performing the calibration, the 1&C technicians did not verify that they were at.the proper pressure switch.
The technicians then performed step 6.3.2 of the procedure which is.to insure that the control switch is turned off by verifying no. voltage is present at the contacts of the switch.
The technicians believed they were on the proper switch when the voltmeter indicated 6.2 mvdc vice the 120 ydc expected, had the switch been energized. _The' location to check for von ge (connectors L1 and L2) was in a a
L tight corner of the sensor box.
It is thougnt that the meter may not have been l
making proper cortact. The technicians then closed the switch isolation valve without using the surveillance procedure; therefore, they did not verify that they were closing the correct valve (step 6.3.3).
Step 6.3.4 requires the test
. connection valve V-130-164 to be opeaed.
Hcwever, the pressure switch for the
'C' EMRV does not have a test connection valve.
T_he technicians proceeded to
? ease pressure to test the switch, when the o
i pressure reached approximate h.070 psig, the 'C' EMRV lifted.
The following corrective action was immediately initiated:
The 'C' EMRV was closed when the control room operator turned the control station switch to off, per procedure. The I&C technicians were instructed to return the pressure switch to service.
The corrective steps that will be taken to avoid further violations include the fol_ lowing:
L l
The 1&C_ technicians involved in this incident will be given a requalification 1
program that will' include a training session on self-checking as well as L.
requalifying on their ' A' core OJT surveillance, and other surveillances as i
assigned by the I&C superintendent.
The I&C technicians involved in the incider.t will conduct a training session for other I&C-technicians on ways to avoid a reoccurrence of this type. of mistake.
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Enclosure.
C321-92-2250 Page 3 of 3 The I&C technicians will not be allcwed to work on safety related systems until they have been requalified by I&C supervision. This is expected to occur by November ;, 1992 In addition, an Engineering Work Request was submitted to investigate the feasibility of moving the suitch terminal points to an area which would allow for easier access in testing. The engineering--evaluation determined that due to environmental qualification considerations moving the switch terminal points :ould be' inappropriate. However, there is a switch replacement modification, currently scheduled for the 15R-outage, which will eliminate the need for access at the
-tenainal points during testing activities.
Full compliance was achieved when the control room operator and Ihc technicians returned the system to its' normal standby configuration on July 5, 1992.
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