ML20150B614

Notice of Violation from Insp on 880125-29.Violations Noted: No Written Safety Evaluation Performed or Other Compensating Operational or Design Measures Implemented for Inoperative Condition of Reactor Bldg Heating Sys

ML20150B614
Person / Time
Site:	Oyster Creek
Issue date:	02/29/1988
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20150B612	List: IR 05000219/1988002 ML20150B609 ML20150B614
References
50-219-88-02, 50-219-88-2, NUDOCS 8803170079
Download: ML20150B614 (2)

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APPENDILA NOTICE OF '/IOLATION GPU Nuclear Corporation . Docket No. 50-219 -

Oyster Creek Nuclear Generating Station (0CNGS) ' License No. DPR-16 As a result of the inspection conducted on January 25-29, 1988, and in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C), the following violations were identified: i A. The Code of Federal Regulations 10 CFR 50.59 permits licensees to make changes in the facility as described in the safety analysis report provided a written safety evaluation is performed which provides the bases for the determination that the change does not involve an unreviewed safety question. Station Pro-cedure 125, Conduct of Plant Engineering, Section 6.8 requires written safety evaluations per 10 CFR 50.59(a) for any change to the plant configuration whether or not the item is considered nuclear safety related.

Contrary to these requirements, on January 27, 1988, it was determined no written safety evaluation was performed o,' other compensating operational or design measures implemented for the inoperative condition of the reactor building heating system relative to its design basis documented in the updated FSAR. This condition, outside of the design basis, was permitted to exist for approximately two years. l This is a Severity Level IV Violation (Supplement I).

B. Technical Specification 6.8.1, specifies that written procedures shall be maintained. Station Procedure 107, Procedure Control, Section 3.3.4 requires a periodic review of procedures be conducted once every two years. This re-  !

view is defined as a documented reading of the procedures to assure it con-tinues to satisfy its objective in a manner consistent with plant requirements.

In addition, the reviewer should contact a "user" of the procedure (operator, technician, etc.) for feedback on adequacy of the procedure.

Contrary to the above, a review of Station Procedure 329, Reactor Building Heating, Cooling, and Ventilation System, on January 29, 1987 indicates that ,

inadequate procedural reviews have been conducted in that Step 2.3.6 describes '

a reactor building temperature indicator on Panel 11R in the control room.

This temperature indicator appears never to have been installed, consequently the procedural error appears to have existed for approximately twenty years.

This is a Severity Level IV Violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, GPU Nuclear Corporation is hereby re-quired to submit to this office within thirty days of the date of the letter which transmitted this Notice, a written statement or explanation in reply, including:

(1) the corrective steps which have been taken and the results achieved; (2) cor-rective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending this response time.

OFFICIAL RECORD COPY DL50-219/88 0003.0.0 8903170079 880229 02 W 88 PDR ADOCK 05000219 G PDR

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APPENDIX B l l

REQUEST FOR FOLLOW-UP INFORMATION l In recognition of the licensee's ongoing engineering and operational reviews of the design and control ramifications of the subject freezing occurrence on January 6, 1988, the NRC requires further information to continue to assess the adequacy of licensee corrective actions. Accordingly, the licensee is requested to address to this office a reply discussing the follcwing issues, submitted within thirty I

days of the date of the letter transmitting this inspection report. This reply should consist of a written statement or explanation of each discussion point.

If the results of ongoing evaluations are not available, the scope of the items under review should be discussed and the date wb^n results will be available should be included.

(1) Discuss the status of ongoing evaluation efforts to determine the minimum temperatures at which the reliable operation of the various safety related components and instruments within the reactor builing is assured. l (2) Discuss any planned or in process review of other plant buildings housing safety-related components, to determine the potential adverse impact of low temperatures.

(3) Discuss the relationship of the a ove evaluation with documented temperature  ;

limitations in the updated FSAR (eg: 55 degree F maximum temperature across I the drywell concrete shield wall; 50 degree F minimum dry bulb temperature for the heated supply air to the reactor building; et. al.).

(4) Discuss the status of ongoing in plant operations department reviews of the adequacy of cold weather contingency plans and the availablility of plant '

components and instrumentation during extreme cold weather conditions.

(5) Discuss (if not addressed in the response to the second violation in Appendix l A) the program of control which provides assurance that plant operation pro- l cedures are consistent not only with system design features, but also with the current status of the system as affected by maintenance, temporary modi- l fication or other activities. j OFFICIAL RECORD COPY DL50-219/88 0004.0.0 02/04/88