ML20198N144
| ML20198N144 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 01/09/1998 |
| From: | Roche M GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-219-97-09, 50-219-97-9, 6L40-98-20013, NUDOCS 9801200278 | |
| Download: ML20198N144 (7) | |
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GPU Nucleer,Inc.
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U.S Route 79 south NUCLEAR
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Tel639 9714000 January 9. 1998 6L40 98-20013 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555
Dear Sir:
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Oyster Creek Nuclear Generating Station Docket No. 50-219 IR 97-009: Reply to Notice of Violations in accordance with 10CFR 2.201, the enclosed provides GPU Nuclear's response to the violations identified in the subject inspection report.
If you should have any questions, or require further information, please contact Brenda DeMerchant, Oyster Creek Licensing Engineer, at 609-971-4542.
Very truly yours, b bbbb Michael B. Roche Vice President and Director Oyster Creek MBR/BDE/gl g {\\
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Administrator, Region I NRC Project Manager NRC Sr, Resident inspector
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Technical Specifications 6.8.1 requires that written procedures shall be established, implemented and maintained that meet or exceed the requirements of NRC Regulatory Guide 1.33. NRC Regulatory Guide 1.33, Appendix A (l.d) recommends administrative procedures for procedure adherence. Procedure 107, Revision 48, " Procedure Control,"
Step 4.2 requires personnel to follow approved procedures as written.
j Contrary to the above, on October 5,1997, a Shift Technical Advisor (STA) conducted a heat balance calculation and did not follow procedure 1001.6, Revision 18, " Core Heat Balance and Feedwater Flow Calculation - Power Range." Specifically, the STA used an unverified computer steam table, and used 1100 psig vice the required 1300 psig sated in Step 5.2 6.
This is a Severity Level IV Violation (Supplement 1).
RcSpenc GPUN concurs with the violation as stated.
1)
Reason for the Violation The reason for the violation was procedural non-compliance. The STA felt that due to his familiarity with the process, and guided by the procedure's calculation worksheet, there was no need for liim to have the procedure in-hand while performing the heat balance calculation. The STA used the compiiter steam table, contrary to procedural requirements, because it was readily accessible, he had used it in the past, and he felt confident in the results it generated. In addition, the STA used i100 psig vice the required 1300 psig because it inore realistically represented plant conditions.
l 2)
Corrective Actions Taken and the Results Achieved:
The STA's have been instructed to follow the procedural requirements and not to l
use the computer steam tables.
I 3)
The Corrective Steps that will be taken to Avoid Further Violations:
Procedure 1001.6 will be reviewed / revised to address any deficiencies, l
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including the procedural inaccuracies in the " fixed losses" and incorrect reference to psig sice psia as identified in the Inspection Report.
Procedure 1001.6 will be revised to clearly identify the requirement to e
document the lleat Balance in a calculatien in accordance with Procedure EP-006 " Calculations" whenever the process is used as a substitute for the Plant Computer System heat balance calculation.
Attachment !
Page 2 A design verification of the procedural heat balance methodology will be performed.
Training of the STA/GSS/GOS will be conducted on the revised procedure (GSS/GOS review and sign heat balance attachments).
4)
The Date when Full Compliance will be Achieved:
Full compliance will be achieved by March 13,1998 (the end of the training cycle) when training on the above identified corrective actions is completed.
Technical Specifications 6.8.1 requires that written procedures shall be established, 2.
implemented and maintained that meet or exceed the requirements of NRC Regulatog Guide 1.33. NRC Regulatory Guide 1.33, Appendix A (2.g) recommends procedures for control of power operations. Procedure 106, Revision 88,"Canduct ofOperations," Step 4.5.2 requires in part, that all altrms and off normal indications be immediately responded to on any panel in the plant and that operators take action as dictated by the appropriate Alarm Response Procedure.
Contrary to the above, in response to control room annunciator alarms, operators did not take actions ea dictated by the appropriate Alann Response Procedure. Specifically, on November 14,1997, operators respon3cd to control room alarm K-6 d," Isolation Condcaser Makeup Valve Open," and took action (cycled the makeup valve without position indication) not specified by Alarm Response Procedure K-6 d, Revision 46.
Additionally, on November 16,1997, operators responded to control room alarm 9XF-2-d,
" Bus C Undcivoltage," and took action (cycled the equalizing switch) not specihed by Alarm Response Procedure 9XF 2-o, Revision 40.
This is a S'everity Level IV Violation (Supplement 1).
Encons GPUll concurs with the violation and offers the following additional information.
With regard to cycling the H lsolation Concenser Condensate Transfer Make-up Isolation Valve, some of the actions taken were not specified in the applicable Response to Alarm Procedure (RAP) Following receipt of the alarrn and loss of position indication, the Shin Supervisor determined that it was necessaiy to verify operability of the make-up isolation valve and hence the operchility of the 'B' isolation Condenscr. As such, the Shin Supervisor instructed the operators to
Page 3 cycle the valve and demonttrate that makeup capability had not been lost. When no shcIl level increase was observed, this valve and its associated Isolation Condenser were declared inoperable and the appli' ble Tech Spec LCO was entered Later in the shill, it was determined that only the position indication had been lost and that the valve was operable. Apparently, the valve was not cycled for r, sufficient length of time to cause a level increase and no local verification of valve stroke was made. As such, GPUN acknowledges that there was some confusion related to verification of valve movement while cycling this valve.
With regard to cycling the equalizing switch on the C Ilattery Charger, some of the actions teken were not specified in the applicable Response to Alarm Procedure (RAP). Following receipt of the alarm, the operators confirmed the low voltage condition (which wss the result of a recent recurring equipment deficiency) but expected voltage to quickly recover as it had in the past. Ilowever, this time the voltage did not recover as anticipated and operators quickly realized this occurrence was different frcm the past. In an attempt to clear the malfunction on the C-1 charger, the operators decided to place the battery charger in the equalize charge mode. While in equalize, the battery output voltage increased thereby clearing the low voltage alarm. It was understood that the charger should not be operated for extended periods in the equalize charge mode, so the charger was placed back to the float charge, hoping the voltage would then be maintained.
Charger voltage again dropped to below the alarm setpoint. At this time, it was determined that the C-1 charger operation was unacceptable, and the C-2 charger was placed in service in accordance with the Response to Alarm Procedure, Placing the llattery Charger in the " equalize" mode is a procedurally controlled maintenance evolution, and is to be performed as corrective action for battery cell low voltage or specific gravity. As such, these actions were inconsistent with the operating procedure instructions.
1)
Reason for the Violation Following receipt of both of these alarms, the operators took some actions that were not described in the Response to Alarm Procedures; however, their actions were not in violation of these procedures. The supenisors directed the operators to take actions beyond the Response to Alarm Procedures but failed to adequately supenise their actions to ensure proper completion.
The Response to Alarm Procedures are written in varying levels of detail based on the complexity and impact of the required operator actions. Generally speaking, the Response to Alarm Procedures are not intended to provide detailed directions for all possible conditions nor to limit or prohibit additional confirmatory and corrective actions.
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' Attachment 1 Page 4 4
These situations fall into the category of
- Operator Judgment Events" as described in the Station's Conduct of Operations Procedure. This procedure states: "If neither an EOP or ADN entry condition is met, the CROs are in a broad category of events known as Operator Judgment Events. The consequences of these events are minor and do not require a pre-planned response on the part of the CRO." As such, it is the responsibility of the operators and supervisors to ensure that they utilize their existing procedures and plant knowledge when responding to plant events for which there are no procedures. In both of these situations, the operators and supervisors failed to adequately assess the situation and their actions.
2)
The Corrective Steps that have been taken and the Rasults Achieved:
Operations hianagement has distributed these violations and the associated NRC hionthly inspection Report to the Operations Supervisors in order to heighten their awareness and sensitivity to this issue.
3)
The Corrective Steps that will be taken to Avoid Further Violations Operations hianagement will reinforce management's expectations and standards regarding procedure compliance and acceptable operator response to alarm conditions during the upcoming training cycle that is scheduled to.be completed by February 6,1998.
Operations hianagement will review and revise the appropriate Response to Alarm Procedures to enhance the existing guidance provided to the operators when responding to these alarms. This review will be completed by hiarch 1, 1998.
4)
The Date When Full Compliance will be Achieved:
In both situations, the actions described in the Response to Alarm Procedure were ultimately taken. As such, full compliance was achieved within the same shift that these discrepancies were identified.
3.
The Code of Federal Regulations,10 CFR, Part 50, Appendix B, Criterion XVI (Corrective Action), requires, in part, that 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 ccrrected.
Contrary to the above, measures had not been established to assure that conditions adverse to quality, such as fai:ures, malfunctions, deficiencies, deviations, defective
Attachment !
Page 5 material and equipment, and nonconformances are plomptly identified aad corrected, as evidenced by the following:
On September 24,1997, operators identified that the "C" battery room inlet air damper (lid not open as required when they attempted to switch to the winter mode. Operators continued to operate the "C" battery ventilation system in winter mode, even though the existing lineup provided reduced ventilation flow due to the closed inlet air damper, until the inspector notified the control room of the abnormal condition on September 26, at which time operators placed the system back to summer mode. On September 30, operations initiated a deviation report (97-759) documenting the inadequate battery ventilation flow in the wii,ter mode, however, management closed the deviation report at review afler maintenance repaired the inlet air damper. On or about October 24,1997, operators repositioned the "C" battery ventilation system to winter mode, however, did not recognize that the inlet air damper failed to open as required. Operators continued to operate the "C" battery ventilation system in winter mode, even though the existing lineup provided reduced ventilation flow due to the closed inlet air damper, until the inspector notified the control room of the abnormal condition on October 27. Operations initiated an equipment deficiency tag for the failed damper, however, did not initiate a deviation report to address the operator performance deficiencies.
Yhis is a Severity Level IV Violation (Supplerient 1).
Ecsvonss GpUN acknowledges that a violation occurred and ofrers the following additional information:
On September 24, the 11attery Room Ventilation System was placed in the winter mode in response to a low battery room temperature.3The operators were aware of the tv,ispositioned damper but felt the reduced ventilation flow was adequate and let the system operate in this manner to increase the room temperature. On September 26,1997, the NRC Senior Resideut inspector discussed the reduced ventilation flow with the Operations Supervisor. As a result of concerns regarding design basis flow rates, the Operations Supervisor decided to return the system to the summer operation made and initiated increased rnonitoring of room temperature until the repairs to the ventilation system could be completed.
When the ventilation system was placed in the winter mode on or about October 24,1997, the damper did not reposition and the assigned operator failed to follow the procedure. The procedure specifically requires that the position of the dampers be physically verified upon transferring between operating modes. Additionally, the operators and supervisors who normally tour this room failed to recognize the abnormal ventilation conditions (reduced flow rate).
Page 6 1)
Reason for the Violation The root cause of this incident was failure to comply with the System Operating Procedure which requires a physical verificatio of the damper positions upon changing system operating modes. Neither the operator who realigned this system nor the personnel who toured this room identified the abnormal ventilation conditions.
2)
The corrective steps that have been taken:
Upon being informed of this condition, the Operators' Supervisor directed that the damper be repaired. The damper was cycled and proper flow was reestablished.
The ventilation system was thoroughly inspected with the following results:
Operations management instructed th'b Fix It Now Team to replace the damper limit switch which was the cause of the damper failing to realign.
The system low flow switch was discovered not to be functioning and was w
subsequently replaced.
The room thermostat heater wu found to be not operable and has been repaired.
A memorandum was issued to all Operations Personnel reminding them of the impact that support systems have on safety system operability, the importance of operating systems in ac;ordance with the plant's licensing bases, and the significance of monitoring and correcting deficient conditions, Operations Management has distributed these violations and the associated NRC e
Monthly inspection Report to the Operations Supervisors in 0 dcr to heighten their awareness and sensitivity to this issue.
As a result of these actions, the ventilation system has been appropriately addressed and no further action is warranted.
3)
Corrective Steps that will be taken to Avoid Further Violations Operations Management will reinforce management's expectations and standards regarding procedure compliance, impact of support systems on safety system operability, and venfication of actions and plant response during the upcoming training cycle that is scheduled to be completed by February 6,1998.
4)
The Date When Full Compliance will be Achieved Full compliance was achieved within the same shift that this discrepancy was brought to the Operations Supervisor's attention.
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