ML20106E208
| ML20106E208 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 01/29/1985 |
| From: | Fiedler P GENERAL PUBLIC UTILITIES CORP. |
| To: | Kister H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8502130254 | |
| Download: ML20106E208 (3) | |
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GPU Nuclear Corporation
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g gf Post Office Box 388 Route 9 South Forked River,New Jersey 08731-0388 E
609 971-4000 I
Writer's Direct Dial Number:
January 29, 1985 Mr. Harry B. Kister, Chief 7
Division of Project and Resident Programs
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U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Kister:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 m
Inspection 84-20 The attachment to this letter provides our response to the Notice of Violation concained in Appendix A of your letter dated December 28, 1984.
L If there are any questions, please contact Mr. Drew Holland at (609) 971-4643.
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?eter B.
Eler T
lice Pre at and Director Oyster Cr k PBF/KB/ dam I
Attachment cc: Dr. Thomas E. Murley, Administrator g
Region I U.S. 'Juclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 j
NRC Resident Inspector Oyster Creek Nuclear Generating Station Forked River, NJ 08731 8502130254 850129 PDR ADGCK 05000219 0
PDR GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation
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Attachment Violation Technical Specification 6.8.1 requires, in part, that written procedures be established, implemented, and maintained.
Contrary to the above, the following are examples in which the Conduct of Maintenance procedure was not properly implemented.
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Station Procedure 105, Conduct of Maintenance, Appendix A, Section 13 requires the Group Maintenance Supervisor or the Job Supervisor complete the Malfunction /Cause section of the Maintenance and Construction Short Form identifying the specific malfunction and cause of the failure or_ problem.
During a review of completed Maintenance and Construction Short Forms conducted on July 30, 1984, many forms were noted on which the
~ Malfunction /Cause section was not completed. Work Request Nos.
16287,- 16266,14372,14617, and 10027, dealing with important to
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safety systems, are examples where the Malfunction /Cause section was not completed.,
2.
Station Procedure 105,' Conduct of Maintenance, Appendix A, Section 2.0 requires the. Department Manager / Supervisor to, indicate on the-
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Maintenance and Construction Short Form if the problem or work request. involves work which is Important-to-Safety as defined in the GPUN Operation Quality Assurance Plan and Appendix B of the Conduct of Maintenance Procedure.
- During a review of completed Maintenance and Construction Short Forms conducted on July 30,1984, 'some ' forms were noted where tasks obviously Important-to-Safety were incorrectly classified. Work Request Nos. 19505,18456,16194, and 15999 dealing with important to safety' systems are examples of tasks which~were incorrectly classified.
This is a Severity Level V Violation.
Response
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. GPUN ' concurs that in the past some Maintenance and Construction
-(M&C) Short Forms were deficient, in that the Malfunction /Cause section ~ of 'the Short Forms had not been completed.
It is the responsibility.of the M&C Production Section Supervisor to complete, along with other _ sections, ' the Malfunction /Cause section
- of the Short Form backsheet. Administrative ' procedures are in. place specifying this requirement and, af ter review, are -deemed sufficient.
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-i Corrective steps taken to correct the immediate problem:
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To prevent a recurrence of this deficiency, the M&C Department
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implemented actions involving Managers and Supervisors to assure
_7 compliance in this area. Specifically, the M&C Director met with y
Foremen, Supervisors, Production Managers, Planners and others to stress the procedural requirement in this area and to remind the attendees of their responsibilities and accountabilities in regards
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to this issue.
i Corrective steps taken to prevent recurrence:
GPUN expects that increased management attention focused on this deficiency will bring it under control.
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i Full compliance date - At the time of identification of this deficiency, immediate steps were taken to bring about full
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i compliance.
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GPUN concurs that there have been Short Forms where tasks were incorrectly classified.
Corrective steps taken to correct the immediate problem:
a It is the responsibility of the Short Form originators to properly identify whether work to be performed is "Important to Safety" or "Not Important to Safety".
The Plant Materici Department then a
reviews that judgment before forwarding the Short Form to M&C.
I Plant Materiel will give increased attention to this area of the
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Short Form and to proper classification of the work to be performed.
a M&C will ensure that such judgement is made on the Short Forms as y
they are received and if the classification appears to be incorrect, they will resolve the issue with the Plant Materiel Department.
Corrective steps taken to prevent recurrence:
Plant Materiel and M&C Department personnel involved in the review of Short Forms have been instructed that increased attention is required in this area to ensure proper classification of work to be a
performed through Short Forms. CPUN expects that this added j
attention in this area will prevent recurrence.
5 Full compliance date - At the time of identification of this deficiency, immediate steps were taken to bring about full compliance.
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