ML20113E247
| ML20113E247 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 06/28/1996 |
| From: | Roche M GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 6730-96-2215, NUDOCS 9607050178 | |
| Download: ML20113E247 (6) | |
Text
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g Post Office Box 388 Route 9 South Forked River.New Jersey 08731-0388 609 971-4000 Writer's Direct Dial Number:
June 28, 1996 6730-96-2215 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555
Dear Sir:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 Inspection Report 96-003: Reply to Notice of Violation In accordance with 10 CFR 2.201, Attachment I provides GPU Nuclear's reply to the Notices of Violation as documented in the subject Inspection Report.
If you should have any questions or require further information, please contact Brenda DeMerchant, Oyster Creek Regulatory Affairs Engineer, at 609-971-4642.
Very truly yours, h
-d Michael B. Roche Vice President & Director Oyster Creek MBR/BDe/gl Attachment cc:
Administrator, Region 1 NRC Project Manager NRC Resident Inspector a C..
- O 9607050178 960628 g0 PDR ADOCK 05000219
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G PDR l' i GPU Nuclear Corporation is a subsidiary of General Pubhc Utikties Corporation
ATTACHMENT I Violation 1:
Technical Specifications, Section 6.8.1, requires that written procedures shall be established, implemented and maintained that meet or exceed the requirements of Regulatory Guide 1.33, Revision 2, February,1978.
Regulatory Guide 1.33, Appendix A lists typical safety related activities that should be covered by written procedures. Equipment Control (tagging)is specified as one of those procedures.
Procedure 108, " Equipment Control," Section 19.0, Temporary Removal and Re-Posting of Tags, requires the tag holder to prepare a " Temporary Removal Request." Procedure 108 also requires the control room operator to verify the request is complete, evaluate the effects of removing the tags and to prepare a " Temporary Removal Switching Order" as requested.
Procedure 108, Section 13.4.1 and 13.4.2, requires the qualified iadividual to remove the tags and position the components in the sequence specified on the switching order and to initial the switching order as each component is positioned.
Contrary to the above on April 21,1996, a " Temporary Removal Request" identified a need to remove the tags from the "A" recirculation pump motor generator set open and closing fuses in the 4160 volt breaker and to reinstall the fuses; however, the " Temporary Removal Switching Order" incorrectly identified the open and closing fuses for the motor generator set field breaker. Additionally, the tags were removed and the fuses reinstalled in the 4160 volt breaker as per the removal request, not in the field breaker in accordance with the switching order.
This is a severity level IV violation (Supplement 1).
Response
GPU Nuclear concurs with the violation as written.
Reason for the violation:
The root cause of this violation is personnel error which can be attributed to lack of attention to detail and poor self-checking practices.
The Control Room operator who processed the request selected the wrong fuses to be reinstalled. The operator who verified the outage failed to detect this error and both operators tailed to exercise an appropriate level of attention to detail.
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6730-96-2215 Attachment I Page 2 The Control Room operator forwarded the temporary removal /reposting switching order to the electricians for execution. The electricians proceeded to remove the tags, reposition the components and reinstall the fuses. The electricians also failed to recognize l
that the switching order listed the incorrect fuses to be reinstalled and installed the fuses as they had been instructed by their supersisor. Both electricians failed to exercise an appropriate level of attention to detail and demonstrated poor self-checking practices.
The electricians should have detected this error based on the information provided on the switching order.
The corrective steD% that have been taken and the results achieved:
When this error was detected the switching order was updated to identify the actual fuses which had been reinstalled. Since these were the fuses that were to be reinstalled based on the original request, the paperwork was updated to reflect the actual conditions in the field.
This incident was discussed with the operators and electricians involved in order to communicate management's expectations with regard to their performance.
The corrective siens that will be taken to avoid further violations:
Operations and Maintenance management will discuss the circumstances surrounding this incident as well as management's expectations with regard to procedural compliance and self-checking with all department personnel as part of the crew briefing process. These briefings will be completed by August 31,1996.
A review of the component identification labels and nomenclature for the recirculation
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pump fuses will be completed and labels / nomenclature revised by July 31,1996.
Date when full compliance was achieved:
Full compliance was achieved on April 22,1996 when deficiencies in the paperwork were immediately corrected upon discovery.
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'O 6730-2215 Attachment I Page 3 Violation 2:
Technical Specifications, 3.5, " Containment," Section 3.5.A.3, states, in part, primary containment integrity shall be maintained at all times when the reactor is critical.
1 Contrary to the above, on April 8 and 9,1996, for a maximum period of about 41 hours4.74537e-4 days <br />0.0114 hours <br />6.779101e-5 weeks <br />1.56005e-5 months <br />, with the reactor at 100 percent power, primary containment was not maintained in that a path to the secondary containment from the torus volume was open through an open containment spray heat exchanger shell side relief valve.
This is a severity level IV violation (Supplement 1).
Response
GPU Nuclear concurs with the violation as written.
l The reason for the violation:
A full description of this event and the actions taken are described in LER 96-004 dated l
May 9,1996.
The root cause of this event was determined to be accidental valve mispositioning during disassembly and cleaning of the 1-2 containment spray heat exchanger. A contributory cause was the installation of thermal relief valves with manual lift levers.
The corrective steps that have been taken and the results achieved:
A walkdown of all four heat exchangers was performed to ensure that the other relief valves were not in the open position.
Interviews were conducted with the maintenance personnelinvolved.
The manual lift levers have been removed from all four containment spray system relief valves, as well as an additional four relief valves located in the Emergency Service Water system.
A discussion of the need to exercise care when working close to plant equipment was conducted with the personnel involved in this maintenance activity and this incident will be reviewed with all maintenance production personnel in upcoming crew meetings.
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6730-96-2215 Attachment I Page 4 The corrective steps that will be taken to avoid further violations:
The physical location of the thermal relief valves will be evaluated to determine if relocating the valve would improve heat exchanger maintainability. This may include rerouting of the relief valve discharge piping to eliminate the interference in removing the heat exchanger head. This evaluation will be completed by December 31,1996.
The date when full compliance will be achieved:
l On April 9,1996, the containment spray pump was restarted and V-21-22 was verified to i
be closed and not leaking. This re-established the isolation boundary for primary containment.
l Violation 3:
10 CFR Part 50, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," specifies required criteria for quality assurance programs for nuclear power plants. Criteria XVI, " Corrective Actions," states, in part, " Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected."
Contrary to the above, in November of 1994, GPU Nuclear installed a modification to the Oyster Creek Containment Spray subsystem that resulted in the system experiencing significant vibration during system operation, and a condition adverse to quality existed at the facility, namely, the failure to perform a technically based assessment of the impact of the vibrations of the Containment Spray subsystem, and this condition adverse to quality was not identified and was not performed until after a licensee Service Water System Operational Performance Inspection Team noted the condition in December of 1995 following which the licensee made a technically based assessment of this degraded condition on system operability.
This is a severity level IV violation (Supplement 1).
6730-96-2215 Attachment I Page 5
Response
GPU Nuclear takes exception to this violation as follows:
The Oyster Creek Generic Mechanical Post Modification Test Procedure (TP200/0) was utilized during performance of post-modification testing and included Test 12, " Vibration and Noise," which states, " Observe all equipment and piping while in operation and verify absence of excessive vibration. Specific data collection not required for this step."
Although this test was not specified for this modification, the test engineer and system engineer both observed the level of pipe vibration. An on site structural engineer was requested to evaluate the pipe vibration and did not consider it significant enough to justify the installation of targets and taking of vibration / displacement data that would be needed for a formal quantitative assessment. This entire sequence of events was undocumented.
During the Service Water System Operational Performance Inspection, the pipe vibration was observed and questioned by the review team. In response, the piping was instrumented, detailed vibration / displacement data was recorded, and a formal assessment -
was performed. The results of the assessment confirmed the original engineering judgment that the vibration was acceptable and did not jeopardize system operation.
Therefore, it was concluded that the system was fully operational and no condition adverse to quality existed.
Additional concerns expressed by the NRC inspector led to instrumenting a second point on the piping system so that relative movements could be obtained and a more quantitative stress calculation could be performed. The results of this evaluation confirmed that the pipe met the B31.1 stress allowable limits and that the system would not fail due to fatigue. The original engineeringjudgement and the previous piping analysis were reconfirmed which re-verified that the piping system was fully operational. Therefore, a condition adverse to quality never existed with respect to piping vibration.
Based on the above, we have concluded the following:
Application of these post modification test requirements should be improved. This will be ef.
. by " Required Reading" of this event by all SU&T personnel and all System Engineers.
Piping vibration has been fully analyzed and it has been determined that a condition adverse to quality does not exist and did not exist previously. Therefore, Appendix B, Criterion XVI was fully complied with.
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