ML20107E214
See also: IR 05000219/1973022
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O.S. ATOMIC ENERGY COMMISSIOh l
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DIRECTORATE OF RECULATORY OPERATIONS
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REGION I
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R0 Jnspection Report No.: 50-219/73-22
Docket No.': 50-219
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{qd,!.Licensce: Jeisey Central Power and Light Company
License No.: DPR-16
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- Pt'iority:
Madison Avenue at Punch Bowl Road
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Morristown, New Jersey
- Category:
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Location: Oyster Creek, Forked River, New Jersey
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Type of Licensee: 1930 Mut. B E (CE)
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Typq of Inspection: Soecial. Announced
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Dr;tes,of Inspection: December 12, 1973
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Dates of Previous Inspection: December 10-12 a6d 18.1973
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. R2po: ting Inspector:
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D..F. Jdhnson
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Accompanying InspecItors:
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[.D.Toth ReaitorInspector
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E. G. Greenman, Reactor I,nspector
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Other Accompanying P.ersonnel:
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R;vicwcd by:
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E. J.
runner,. Chief, Reactor Operations Branch
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9604190246 960213
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DEKOK95-258_
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SUMMARY OF FINDINGS
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Enforcement Action
None
Licensee Action on Previously Identified Enforcement Items
Not inspected
Unusual Occurrences
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None
O ther Significant Findings
A.
Current Findings
1.
The licensee agreed to update their current facility procedures
to comply with the latest industry standard ANSI N.18.7 and
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The licensee has established a standard format consistent with
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the requirements of ANSI N.18.7 for all facility procedures and
efforts are in progress for revision of current facility procedures.
3.
The licensee stated a QA plan and implementing procedures would
be completed by March 1, 1973.
Management Interview
A management interview was conducted December 12, 1973 with Mr. D. A.
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Ross, Manager, Nuclear Generating Stations and Mr. J. T. Carroll, Station
Superintendent.
Items discussed are summarized below.
A.
General
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The inspectors described the scope of the inspection related to an
overview of the licensee's procedural status. The requirements for
procedure development, review and revision to assure compliance with
ANSI 18.7 and Regulatory Guide 1.33, were discussed.
B.
Independent Review for Procedures
The inspector stated that PORC approval did not constitute an offsite
or independent review, and further referenced the necessity for review
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by some organization separated from daily plant operation.
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A licensee representative asked if a corporate management
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representative and engineering staff would fulfill these
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requirements.
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The inspector stated that such a review could be considered as
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independent.
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C.
Procedure Development
The . inspector stated that a comparison of the licensee's procedures
with Regulatory Guide 1.33 indicated additional procedural coverage
was required.
(Details, Paragraph 2)
D.
Housekeeping
The inspector stated that a tour of the facility indicated substantial
improvements.
Specifically, the repainting of the 51' elevation level.
The inspector noted color coding of system piping and painting of
mechanical equipment.
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A licensee representative acknowledged the inspector's remarks and
noted that similar work was to be done throughout the plant.
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QA Program for Operations
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The inspector requested a status report for the QA Program for
Operations.
Staffing and manpower requirements were discussr.d
in detail.
A licensee representative stated that the plan is in draf t form and
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the staff is currently writing implementing procedures.
F.
The inspector stated that Oyster Creek's facility procedures are
generally not consistent with content requirements of ANSI N.18.7
in the following areas:
Statements of Applicability
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References and Cross References
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Prerequisites
Limitations and Corrective Actions
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Check-offs and Check-lists
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Identification of Technical Specifications where applicable
(Details, Paragraph 3)
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DETAILS
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Persons Contacted
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D. : Ross, Manager, Nuclear Generation
J. Carroll, Station Superintendent
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D. Reeves, Chief Engineer
J. Sullivan, Operations Engineer
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R. Swif t . Maintenance Engineer .
J. Maloney, Operations Supervisor
E; Growney,: Technical Engineer
E. D. Scalsky,' Radiation Protection Supervisor
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2.
Oyster Creek's facility procedures are adequate and in compliance with
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their license requirements, however, additional procedural coverage
and revision of existing procedures in the following areas would be
necessary. to be in complete compliance with the current industry-
standard ANSI N 18.7 and Regulatory Guide 1.33.
a.
Administrative controls for:
(1) Authorities and responsibilities of the plant staff for
safe operation and sbutdown of the facility.
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(2) Adherence to procedures, checklists and prerequisite
approvals for determining a procedural step as "not
applicable."
(3) Shift and relief turnover.
(4) Record retention and retrievability.
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Surveillance test and calibration schedules.
(6) Bypassing of safety functions and jumper control.
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Implementing the corrective and preventive maintenance
program.
.(8) . Preparation of procedures, which adopts ANSI N.18.7 and
Regulatory Guide 1.33 requirements and which also describes
the mechanics of review and approval.
(9)- Actions relative' to check offs of non-applicable items and
system operational requirements when portions of the system
are permitted to be out of service.
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b.
Operating procedures for:
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(1) Communication systems.
c.
Emergency procedures for:-
(1) Loss-of-coolant inside and outside the 'drywell.
(2) Abnormal releases of radioactivity.
(3) High stack releases when shutdown.
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d.
Maintenance procedures for:
(1)L Safety related systems and components.
- Licensee's Responne
A licensee representative concurred with the inspector's comments
and agreed to review facility procedures to ensure coverage in the
above areas.
'3.
Review of selected operating and emergency procedu'res ' identified the
following areas which require upgrading to meet ANSI N 18.7 and Regu-
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latory Guide 1.33.
a.
Clarification of whether or not complete establishment of
" Initial Conditions" is required before beginning the proce-
dures' steps.
b. . Assuring conformance of checklists with steps in the body of
the procedure.
c.
Assuring that precise procedural steps cover imprecise terms
which do not have quantitative control guides.
Examples include:
(1) Appropriate instrumentation.
(2) Proper Valving.
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Specified withdrawal sequence.
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(5) Available.
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(6)
Normal level.
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In-opera tion.
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(8)
In-service.
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d.
Assuring, as key systems are brought on the line, that process
parameters are, in each case, checked against quantitative limits
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to confirm acceptable operational status before attempting the
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next step.
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c.
A6.uring that procedures instructing the operator to operate a
system or component reference the specific procedure containing
precautions, limitations, and step by step operating instructions
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for the operation involved.
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Assuring that required review of plant status prior to startup
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is sufficiently detailed.
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g.
Assuring that energency procedures highlight primary symptoms
without requiring discrimination between multiple, separate,
and long lists of conditions.
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Assuring that emergency procedures properly delineate investigative
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steps taken subsequent to the immediate response to an alarm.
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i. Assuring that alarm clearing procedures generally refer to the
Technical Specifications and the other alarms and procedures which
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must be consulted.
j. Assuring that actions to be taken for alarm conditions are compiled
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Assuring that emergency procedures require specific notification
of plant personnel about the nature of the emergency and confirma-
tion of the status of the plant.
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Assuring that the putpose or intent of each procedure is clearly
defined.
Assuring that procedures provide specific acceptance criteria
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and cover restoration to normal operation af ter evolutions,
Assuring that procedures contain appropriate references to
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engineering flow diagrams, technical manuals, and other perti-
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nent procedures.
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for the operator.
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Inspector's Comment
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The inspector emphasized that this was a sampling inspection which
indicated that all facility procedures should be reviewed for similar
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conditions and ' for other requirements of ANSI N 18.7 and Regulatory
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Guide 1.33.
The licensee stated that he concurred with the inspector's comments.
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