ML20151Z586
| ML20151Z586 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 09/11/1998 |
| From: | Eselgroth P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Roche M GENERAL PUBLIC UTILITIES CORP. |
| References | |
| 50-219-98-03, 50-219-98-3, NUDOCS 9809220031 | |
| Download: ML20151Z586 (2) | |
See also: IR 05000219/1998003
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September 11,1998
Mr. Michael B. Roche -
Vice President and Director
GPU Nuclear, Inc.
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Oyster Creek Nuclear Generating Station
P.O. Box 388
Forked River, New Jersey 08731
SUBJECT:
INTEGRATED INSPECTION 50-219/98-03
Dear Mr. Roche:
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This letter refers to your August 14,1998 correspondence, in response to our
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July 17,1998 letter.
Thank you for informing us of the corrective and preventive actions documented in your
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letter. These actions will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
Sincerely,
Original Signed By:
Peter W. Eselgroth, Chief
Projects Branch 7
Division of Reactor Projects
Docket No.: 50-219
cc w/o cv of Licensee Resoonse Letter:
M. Laggart, Manager, Licensing and Vendor Audits
G. Busch, Manager, Nuclear Safety and Licensing
ec w/cv of Licensee Resoonse Letter:
State of New Jersey ,
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Mr. Michael B. Roche
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Distribution w/cv of Licensee Response Letter
Region 1 Docket Room (with concurrences)
Nuclear Safety information Center (NSIC)
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PUBLIC-
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NRC Resident inspector
H. Miller, RA/W. Axelson, DRA
P. Eselgroth, DRP
N. Perry, DRP
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D. Haverkamp, DRP
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C. O'Daniell, DRP.
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J. Yerokun, DRS
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B. McCabe, OEDO
C. Thomas, PD1-3, NRR
R. Eaton, PD1-3, NRR
T. Colburn, PDI-3, NRR
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R. Correia, NRR
F. Talbot, NRR
DOCDESK
Inspection Program Branch, NRR (IPAS)
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DOCUMENT NAME: G:\\ BRANCH 7\\REPLYLTR\\OC9803,RPY
T3,oceive a copy of this document, indicate in the box:
- C" = Copy without attachment / enclosure
- E' = Copy with attachment / enclosure
- N' = No copy
OFFICE,
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DATE
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09/}l/98 ~
09/)l/98
OFFICIAL RECORD COPY
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GPU Nuclear. Inc.
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U.S. Route #9 south
. NUCLEAR
Post Office Box 388
Forked River, NJ 087310388
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Tel 609-9714000
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August 14, 1998
1940 98-20458
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U. S. Nuclear Regulatory Commission
Attention: . Document Control Desk
Washington, DC 20555
Dear Sir:
Subject:
Oyster Creek Nuclear Generating Station
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Docket No. 50-219
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IR 98-003: Reply to Notice of Violations
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in accordance with 10CFR 2.201, the enclosed provides GPU Nuclear's response to the
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- violations identified in the subject inspection report.
If you should have any questions, or require further information, please contact Brenda
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DeMerchant, Oyster Creek Regulatory Affairs Engineer, at 609-971-4642.
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Very truly yours,
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Michael B. Ro e
{kVice President and Director
Oyster Creek
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Attachment
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cc:
Administrator, Region I
NRC Project Manager
NRC Sr. Resident Inspector
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Attachment I
Violation 1
The Code of Federal Regulations,10 CFR, Part 50, Appendix B, Criterion XV (Nonconforming
Materials, Parts, or Components) requires that measures shall be established to control materials,
parts, or components which do not conform to requirements in order to prevent their inadvertent
use or installation. These measures shall include, as appropriate, procedures for identification,
documentation, segregation, disposition, and notification to affected organizations.
Nonconforming items shall be reviewed and accepted, rejected, repaired or reworked in
accordance with documented procedures.
Oyster Creek Nuclear Generating Station (OCNGS) procedure 125.2.10, Receipt Deficiency
Reports, revision 2, requires, in part, the action party for a deficiency to provide a proposed
disposition to resolve the deficiency (Use-As-Is, Repair, Rework, Scrap, Other), and the
Configuration Maintenance Manager to evaluate the proposed disposition and either concur or
provide the required disposition.
Contrary to the above, on or about June 9,1998, the licensee failed to review and disposition a
nonconforming emergency diesel generator starter motor in accordance with OCNGS procedure
125.2.10.
This is a Severity Level IV violation (Supplement I).
Response
GPU Nuclear concurs with the violation as written.
Reason for Violation
Due to the fact that the plant was in a Technical Specification Limiting Condition for Operations,
thejob supervisor was focused on replacing the Number 1 Emergency Diesel Generator (EDG)
starter motor with an in kind replacement thus overlooking the administrative requirement to
disposition the deficiency of the nonconforming starter motor per Procedure 125.2.10.
During pre-service testing the starter motor failed to respond as required and the supervisor was
informed of the problem. During the supervisor's investigation he realized that a jumper was
installed that set up the starter motor for single operation rather than two starters in series as
required for Oyster Creek's diesels. Based on his knowledge and experience, thejob supervisor
directed that the replacement starter be configured to match the installed starters and that the
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starter be fully tested in accordance with approved procedures. The starter tested satisfactorily
and was installed in the Number 1 EDG. Post maintenance testing was performed satisfactorily
and the EDG was returned to operation.
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The fact that Procedure 125.2.10 was not followed was identified during the cognizant engineer's
post maintenance review.
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Attachment I
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1940-98-20458
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Page 2 of 6
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Corrective Stens Taken and Results Achieved
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Corrective Action Program (CAP) repons were generated to investigate the failure to document
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the deficient condition and to determine if a 10 CFR 21 report should be made. Also, a Receipt
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Deficiency Report (RDR) was written to capture action taken to configure the starter motor.
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This RDR was dispositioned to use the staner motor as configured with thejumper removed.
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Corrective Stens Taken to Avoid Further Violations
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An additional CAP was generated to document the failure to administratively control the
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configuration change to the staner motor.
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As per 10CFR, Pan 50, Appendix B, Criterion XV, measures are in effect under OCNGS
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procedure 125.2.10 to manage configuration control preventing inadvertent use or installation of
material. This event occurred due solely to an inappropriatejudgement by the supervisor. The
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superdsor has discussed configuration control with the Electrical Superintendent and the
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Configuration Control Manager. This event has also been discussed in the electrical shop
meetings.
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A review of the need to submit a 10 CFR 21 report in accordance with GPUN procedure 1000-
ADM-1290.01 is ongoing.
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Date When Full Comoliance was Achieved
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Full compliance was met when the Receipt Deficiency Report (RDR) was dispositioned as stated
above.
Violation 2
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License Condition 2.C.3, Fire ProteGinn, of Facility Operating License DPR-16, for the OCNGS,
states, in part, "GPU Nuclear Co9 oration shall implement and maintain in effect all provisions of
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the approved Fire Protection Program as described in the Updated Final Safety Analysis Report
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supplements thereto.'.."
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Section 9.5.1, Fire Protection Systems, of the Updated Final Safety Analysis Repon, states that
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OCNGS procedure 101.2, Fire Protection Program, is considered included in the Fire Protection
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Program.
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Att chment I
1940-98-20458
Page 3 of 6
Contrary to the above, GPU Nuclear Corporation did not implement and maintain in effect all
provisions of the approved Fire Protection Program as indicated by the following examples:
A.
OCNGS procedure 101.2, Fire Protection Program, directs that fire watches be
established in accordance with OCNGS procedure 120.2, Fire Watch Instructions.
Section 4.2.2, OCNGS procedure 120.2, Fire Watch Instructions, Subsection 4.2.2.1.3
requires that a fire watch turnover shall include a review of the Fire Watch Assignment
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Forms.
On May 18,1998, the fire watch turnover failed to include a review of the Fire Watch
Assignment Forms.
B.
Section 4.4, OCNGS procedure 101.2, Fire Protection Program, states, in part, that fire
watches shall provide required notification and possible extinguishment of a fire when a
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fire protection system is impaired or inoperable.
On August 1,1997, no fire watch was assigned to provide notification and possible
extinguishment of a fire in the exciter when the turbine generator exciter high pressure
CO system was inoperable.
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This is a Severity Level IV violation (Supplement I).
Response to Examnie "A"
GPUN concurs with the violation and offers the following additional information:
Reason for Violation
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Due to their familiarity with the existing impairments, the firewatch personnel used the Fire Watch
Inspection Log which provides a listing ofimpairments rather than the individual Fire Watch
Assignment Forms as described in the procedure. Even though the individual forms were not
reviewed, the firewatch was knowledgeable of the impairments and performed an appropriate
tour.
Corrective Steps Taken a d Results Achieved
Management's expectations were reviewed with all firewatch personnel regarding their roles and
responsibilities. In addition, a review of proper turnover techniques including usage of the
Inspection Log and the Assignment forms, and the purpose for both of these documents was held
with all firewatch personnel.
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Attichment I
1940-98-20458
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Corrective Stens Taken to Avoid Further Vi' lations
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Tr.e Fire Protection Coordinator has distributed these violations and the associated NRC
Inspection Report to the fire watch personnel and operations supervisors in order to heighten their
awareness and sensitivity to these issues.
The Fire Protection Coordinator has reinforced management's expectations and standards
regarding procedure compliance and proper turnover techniques with all fire watch personnel.
The Fire Protection Coordinator will review and revise (as appropriate) the Fire Watch
Instructions regarding the turnover process to enhance and simplify our existing process. The
appropriate revisions will be completed by November 1,1998.
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Date When Full Comoliance Was Achieved
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Full compliance was achieved on August 7,1998 with issuance of a memorandum reinforcing
management's expectations and standards regarding proper turnover techniques.
Response to Example "B"
GPUN concurs with the violation as written.
Reason For Violation
When the turbine generator exciter high pressure CO2 system was removed from service to
support routine maintenance activities, a fire watch was not assigned because of a procedural
deficiency. The turbi::e generator exciter high pressure CO2 system is not contained in the Oyster
Creek Fire Protection Program Technical Requirements (Attachment 101.2-3). This attachment
provides fire watch requirements for inoperable fire detection equipment, suppression systems and
associated instrumentation in safety related areas and zones. Since the exciter is not a safety
related or safe shutdown required component, no specific compensatory measures are contained
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within Attachment 101.2-3. As such, a firewatch was not assigned when this system was
removed from service contrary to the requirements of the plant's Fire Protection Program.
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Attachment I
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1940-98-20458
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Page 5 of 6
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Corrective Stens That Have Been Taken And The Results Achieved.
Procedural changes have been implemented to define and clarify the compensatory measures for
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. balance of plant systems and components within the Oyster Creek protected area. Revision 28
was issued to Procedure 101.2, effective June 15,1998, which provides clarification and
additional directions.
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Corrective Stens That Will Be Taken To Avoid Further Violations
Following the exciter fire, the following additional precautions were instituted to preclude
recurrence:
Revised the PM task for exciter maintenance to add a precaution for portable fire
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extinguishers to be staged prior to removing the system from service and for personnel
exiting the area to ensure the doors to the area are closed.
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Instmeted Operations to minimize the time period that the CO2 Suppression System was
out of service.
Established a requirement to assign an hourly firewatch whenever the exciter suppression
system is out of service for longer than eight hours.
Date When Full Compliance Was Achieved
Full compliance with the requirement to appropriately identify and assign firewatches for non-
safety related/ safe shutdown areas was ach eved on June 15,1998 when the revised procedure
became effective.
Violation 3
License Condition 2.C.3, Fire Protection, of Facility Operating License DPR-16, for the OCNGS,
states, in part, " GPU Nuclear, Inc. shall implement and maintain in effect all provisions of the
approved Fire Protection Program as described in the Updated Final Safety Analysis Report for
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the facility and as approved in the Safety Evaluation Report dated March 3,1978, and
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supplements thereto..."
Section 3.2.4, Communications Equipment, of Supplement No. 3 to the Safety Evaluation Report
dated March 3,1978, requires the licensee to install fixed repeaters to assure that adequate
communications capability would be available for fire fighting and safe shutdown activities.
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Attachment I
1940-98-20458
Page 6 of 6
Contrary to the above, on or before August 1,1997, communications that were required for fire
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fighting and safe shutdown activities were inadequate. Specifically, the licensee failed to
adequately maintain and test the installed radio repeater backup battery power supply.
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This is a Severity Level IV violation (Supplement I).
BEWPER
GPUN concurs with the violation as written.
Reason for Violation
The violation occurred due to inadequate preventive maintenance. The preventive maintenance
on the radio communication system did not adequately maintain and test the installed radio
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repeater backup battery power supply.
Corrective Stens That Have Been Taken and The Results Achieved
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The radio communication repeater's backup batteries were replaced on November 24,1997. The
repeater was then tested on battery power only to verify proper operation. Radio repeaters are
working normally with backup battery power on a float charge.
Corrective Stens That Will Be Taken to Avoid Further Violations
A preventive maintenance task was written to replace repeater batteries every four years. In
addition, a preventive maintenance task was developed to perform a yearly float voltage check on
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the repeater backup battery power supply. All preventive maintenance tasks have been written
and scheduled.
Date When Full Compliance Was Achieved
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Full core; mee for the repeater backup batteg power supply was achieved on November 24,
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1997, when the batteries were replaced and tested.
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