ML20138H818
| ML20138H818 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 04/30/1997 |
| From: | Roche M GENERAL PUBLIC UTILITIES CORP. |
| To: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 6730-97-2135, CAL-1-97-08, CAL-1-97-8, NUDOCS 9705070295 | |
| Download: ML20138H818 (3) | |
Text
..
e-
{
GPU Nuclear,Inc.
)
(
U.S. Route #9 South I
NUCLEAg Post Office Box 388 Forked River, NJ 08731-0388 Tel 609-9714000 l
6730-97-2135 April 30,1997 1
Mr. Hubert J. Miller, Administrator J
US Nuclear Regulatory Commission Region I 475 AllenaaleRoad King ofPrussia, PA 19406-1415
Subject:
Q ster Creek Nuclear Generating Station (OCNGS)
!Eility License No. DPR-16 Docket No. 50-219 Response to Item 2 of Confumatory Action Letter (CAL) 1-97-008 Re: Quality Classification of Selected Plant Components at OCNGS
Dear Mr. Miller:
Item 2 in CAL 1-97-008 follows:
"2.
Determine the impact of the equipment classification downgrade program, as implemented, at TMI and Oyster Creek.
i You should report the completion of this item by letter addressed to the Regional Administrator, NRC Region I, dated on or before April 30,1997."
This letter res;oris to this specific item for OCNGS.
Immediate corrective action'was taken in response to the issues raised concerning the quality classification list (QCL). Steps were taken to preclude additional inappropriate instances of equipment classification downgrades. Work on further programmatic equipment classification downgrades was stopped pending pre ', dure and training upgrades and a process was established i
to review planned day-to-day maintenance and modiScation work involving equipment that was downgraded in order to assure that parts t. 6e correct quality clas ification are used.
y
- f~
Wb nsil.lM,IBIlllIIIIBIlllll
.. i
-n
- t 'l 9705070295 970430 PDR ADOCK 05000219 G
i Mr. Hubert J. Miller 6730-97-2135 Page 2 of 3 i
Downgraded equipment can be placed in the following three categories: 1) items initially classified as " nuclear safety related" (NSR) and downgraded to " regulatory required" (RR) or "Other with QA" or "Other aithout QA"; 2) items initially classi6ed as RR and downgraded to "Other with QA"; and 3) items initially classified as RR and downgraded to "Other without QA" For the category of 605 items initially classified as NSR, item lists were posted and utilized to prevent unreviewed activities until safety.eviews could be conducted which confirmed the L
downgraded classification or af5rmed the original NSR classification. Safety reviews on all these
' items have been completed. During the review, the Oyster Creek Deviation Report corrective action process was used to address operability concerns. As a result,16 items required re-l classification to NSR. The impact of the equipment classification downgrade program on previously classified NSR items at Oyster Creek was determined by evaluating the operability of.
the specific components. Operability reviews were completed and concluded that none of the I
mappropriately classified NSR components affected operability.
i i
All 1530 components that were downgraded from RR to "Other with QA" had their classification returned to RR. The impact of this downgrade was minimized for the following reasons.
Although the classification was downgraded, materials and parts for the downgraded components were not prommmatically downgraded and most of the parts swiained at tne RR classification.
For compontch.n the preventive maintenance program, a review revealed that 15 of 1136 parts required material upgrading. All parts in this category had procedural requirements for istnllation, testing, maintenance or surveillance. Existing maintenance procedures required a check of new parts against installed parts and required post maintenance testing. Based on the above reviews, GPU Nuclear concludes that there was no adverse impact on equipment.
All 449 components downgraded from RR to "Other without QA" were evaluated. The evaluad
, oncluded that 294 be returned to RR and the rest remain as "Other without QA". The i
impact of the downgrade on these 294 items was minimized for similar reasons to those downgraded to "Other with QA" from RR. Materials and parts for the downgraded components vere not programmatically downgraded and most remained at the RR classification. Existing maintenance procedures required a check of new parts against installed parts and required post maintenance testing. Based on the above reviews, GPU Nuclear concludes that there was no adverse impact on equipment.
GPU Nuclear took action to ens'.:re that QCL deficiencies with a potential to impact plant safety were addressed. For the components with the greatest potential impe.ct on safety (NSR), a review of the deviations resulting from the safety reviews indicated no affect on the operability of those j
components. Most materials and parts for downgruded RR components remained rd the RR i
classification. This, combined with the controls employed through maintenance procedures, j
provides reasonable assurance that repaired components are operable and reliable, d
!c l
)
Mr. Hubert J. Miller 6730-97-2135 Page 3 of 3 l
Based on the above, GPU Nuclear concludes that, although deficiencies existed in the QCL, appropriate action was taken to minimize any affect on safe plant operation including the implementation of corrective action.
Ifyou should have any questions concerning the information in this letter, please contact Mr. Paul l
Czaya, Regulatory Affairs Department, at 609-971-4139.
l l
Very truly yours, l
hfh Michael B. Roche j
Vice President and Director Oyster Creck MBR/PFC l
c:
USNRC Document Control Desk 1.
Oyster Creek NRC Senior Resident Inspector i
Oyster Creek NRC Project Manager l
i
. _..