ML20203B301
| ML20203B301 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 12/04/1997 |
| From: | Roche M GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-219-97-07, 50-219-97-7, 6730-97-2279, NUDOCS 9712120405 | |
| Download: ML20203B301 (5) | |
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Te! 639 97,M December 4, 1997 6730-97-2279 U. S. Nuclear Regulatory Commission Attention Document Control Desk Washington, DC 20555
- Dear Sir;
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 IR 97 007: Reply to Notice of Violations In accordance with 10CFR 2.201, the enclosed provides CPU Nuclear's response to the violations identified in the subiect inspection report.
If you should have any questions, or require further information, please contact Brenda DeMerchant, Oyster Creek Regulatory AfTairs Engineer, at 609-971-4642.
Very truly yours, 10 h+<DL Michael B. Roche Vice President and Director Oyster Creek MBR/BDE/gl Attaciunent I
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_ Administrator, Region I
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NRC Project Manager
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NRC Notice of Violation No 1 The Code of Federal Regulations,10CFR, Part 50, Appendix D, 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 nonconformar:es are promptly identified and corrected.
Contrary to the above, measures h id not been established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nor.conformances were promptly corrected.
On November 20,1995, the licensee identified that the 'C' battery room heating, ventilation, and air conditioning (llVAC) air outlet duct thermostat temperature switch did not bring in control room alarm U 8-f. As of October 5,1997, the licensee did not take adequate action to correct this condition. On December 27,1994, the licensee identified that 'C' battery room llVAC dampers did not work correctly as the air inlet damper did not close when the IIVAC mode switch was selected to summer. On November 22,1995, Maintenance completed Job Order 59515 to correct the December 27,1994 problem.
On April 9,1997, the licensee identified that the 'C' battery room dampers did not respond when the 'C' battery room IIVAC mode switch was taken from winter to summer. On May 29,1997, Maintenance completed Job Order 516054 (corrected number) to correct the April 9,1997, deficiency. On September 24,1997, the licensee identified that the 'C' battery room inlet air danmer was not opening as required in the winter mode. The above deficiencies adversely affected operations as proper 'C' battery room ventilation was not reliably maintained and no indication of abncmial 'C' battery room temperature existed in the control room.
This is a severity 1.evel IV violation.
Ecsponse:
GPUN concurs with the Violation as written:
][tason for Violatioq; This violation occurred due to inadequate maintenance attention to the instrumentation and controls systems associated with the 'C' battery room 11VAC system. The Maintenance program asss :iated with the damper section consisted of the mechanical " Clean and Inspect PM" and the Operations " Cycle to Prevent llinding PM". 'Ihese PMs do not however test the control systems.
Corrective Steps Taken and Results Athlettd1 The ventilation heater has been repaired and the temperature switch was tested. This confirmed proper functioning of the alarm circuitry associated with Alarm U 8 f. Parts have been ordered to replace the limit switch and flow meter on an expedited basis and are due by the end of hiarch,1998. Additionally, a deviation report was issued to develop a Preventive hiaintenance Task to assure proper controls settings.
Corrective Action to A. void Further Violatlanit Development of the Preventive hiaintenance Task, to verify proper control settings and function along with calibration checks of the instruments, in conjunction with the performance of the existing hiechanical hiaintenance and Electrical hiaintenance tasks. Until the alarm function is returned to r.onnal, Operations' daily tours have been modified to conduct shiftly tours of the "C" battery room instead of the previous daily tour, hie When Full Compliance Will lic Achieved:
Full compliance with regulatory requirements will be achieved when the flow meter is calibrated and -
replaced and the Instrumentation Preventive Maintenance Task is authorized.
Additional corrective actions are in progress and expected to be completed by April 30,1998.
NRC Notice of Violation No 2 Technical Specification 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 (9.c) recommends general procedures for the control of maintenance, repair, replacement, and modification work, including information such as a method for obtaining pennission and clearance for operation personnel to work and for logging such work.
Oyster Creek procedure 105, " Conduct of hiaintenance", Step 4.3.1.1 (L), requires that work is to be perfonned in accordance with the approved Job Order, in cases where the job requirements or scepe i-change the intent of the Job Order, the planning Group will revise the job package.
Contrary to the above, on September 30,1997, work was not performed in accordance with an approved Job Order in that electricians conducted work underjob package 518534, where the scope changed beyond the intent of the Job Order, and the Planning Group did not revise job package 518534.
Specifically, electricians conducted troubleshooting activities on the automatic voltage control portion of the main generator exciter voltage regulation c.ircuit using existing Job Order 518534, originally scoped to replace a failed automatic voltage control relay.
This is a severity Level IV violation.
t Responsgi j
t GPUN Concurs with the Violation as written Reason for Violation This violation occurred due to human performance error. Personnel assigned to this task failed to o
realize that the action of closing the 43m contactor would operate the contacts that placed the amplidyne into the voltage regulator circuit. This was known by the supervisor briefmg the task, however, his mindset and focus of the main job at hand, of replacing the 43m relay, took precedence over his recalling the other contacts. Neither the engineers nor the technicians considered that changing the state of the contactor from open to closed would affect anything else, This lack of consideration was due largely to the print showing the 43m contact not containing the associated cortact development. The technicians therefore believed they were working within the scope of the existing work controlling document.
Corrective Steos Takin_pnd Results Achieved:
Data taking steps were secured and, once the 43m contactor was released, the main generator returned to steady state conditions. The electricians researched the applicable prints and determined the cause of the swings in vars of the main generator. A Deviation Report was issued, a Maintenance Critique was performed and a Performance Enhancement Review Committee (PERC) meeting was held.
Immtdiate Corrective Action:
All further maintenance activities on this equipment were stopped by the Maintenance Director. The Maintenance Director met with the Electrical Shop craft and supervisors to discuss the following:
Communicate all relevant information to Operations prior to the start of work.
Questioning the Job Packages to ensure that the work being perfermed is within the scope of the Work Controlling Document.
Back shift work will be conveyed to Operations by a first line supervisor or lead technician prior to work commencing on that shift Additionally, the first line supenisor involved in the task briefing formally discussed the event with the Maintenance Director and the superintendent. The technicians and supervisor involved were debriefed independently to determine if any immediate corrective actions were required.
The Maintenance Director also met with the other shop superintendents to discuss work control.
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Additional Corrective Actions are as Follows:
I knins tion of the amplidyne revealed no damage.
An Engineering Change Document (ECD) will be submitted to update DWG #GE 44D320425 Sheets 1 and 2 to include relay and contact development j
Maintenance management will establish specific guidance as to when a troubleshooting action plan is expected to be developed.
In addition to the discussion held with the Electric Shop, similar discussions will take place for the other maintenance disciplines. Additionally, Engineering managers will brief their personnel on this incident and discuss the need to be active participants in all phases of troubleshooting. It will be emphasized that when using an old print all parties involved must review all sheets of the print being used.
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Date When Full Comnliance Will Be Achieved:
Full compliance with regulatory requirements was met when the data taking evolution was secured on the same day as the violation.
Additional corrective actions are in progress and expected to be completed by December 31,1997.
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