ML20207E338

Responds to NRC Re Violation B Noted in Enforcement Conference Rept 50-219/86-12 on 860912. Corrective Actions:Unescorted Access Denied to QA Project Manager Improperly Certifying Project Completion in 1984

ML20207E338
Person / Time
Site:	Oyster Creek
Issue date:	12/19/1986
From:	Manganaro F GENERAL PUBLIC UTILITIES CORP.
To:	Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
FFM-86-157, NUDOCS 8701020145
Download: ML20207E338 (3)

Text

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. xo GPU Nuclear Corporation NgIgf Post Office Box 388 Route 9 South Forked River,New Jersey 08731-0388 609 971-4000 Writer's Direct Dial Number:

December 19, 1986 l, Dr. Thomas E. Murley, Administrator Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406

Subject:

Oyster Creek Nuclear Generating Station Docket No. 50-219 IE Inspection 50-219/86-12, Enforcement Conference Your letter dated November 17, 1986 documented an Enforcement Conference held 3 with GPU Nuclear at the Region I headquarters on September 12, 1986. J Attachment A to your letter details two violations which were originally ,

defined in IE Inspection Report 50-219/86-12. f f

Your letter states that no response is required for Violation A as the 2 corrective action has been completed. Attachment I to this letter provides GPU f Nuclear's response to Notice of Violation B. An extension of the due date to 7 December 22, 1986 was granted by Mr. R. Conte of the NRC on December 16, 1986. y k

If any further information is required, please contact Mr. John Rogers at g (609)971-4893. g Very truly yours, h 8701020145 861219 PDR ADOCK 05000219 / Frank F. ganaro G PDR Vice Pr ent & Director '

Mainten e, Construction

& Facilities ,

FFM:JJR: dam Attachneent  !

cc: Mr. Jack N. Donohew, Jr.

U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue, Phillips Bldg.

Bethesda, MD 20014 -

NRC Resident Inspector

. Oyster Creek Nuclear Generating Station GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation y WG\ $

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December 19, 1986 I J -

ATTACHMENT'I.

Ltr. #FFM-86-157 N,,.

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4 Violation B l

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'10.CFR 50_ Appendix B,' Criterion ~VII and Section 5.0 of-the Oy' ster Creek Operations.' Quality Assurance Plan require, in part,'that measures be established to assure that purchased services conform to procurement r' < P documents. These measures shall. include objective evidence of quality

? furnished by the_ contractor. Also, the' effectiveness of the control of

-. quality by. contractors shall be assessed consistent with the importance Jand complexity of the' service.-

r y { Contrary to the above, control of. quality of contractor work performed on

~

- ' snubbers was not effectively assessed in that four inoperable snubbers

- existed due to missing clamp to lug welds on the Isolation Condenser

? - System, following work on the' system by a contractor during a 1983-1984 outage..and these deficiencies were not identified until 1986.

Response

- GPUN concurs in the violation.

-The'cause of the violation'was identified as a contractor at the Oyster

~ Creek site performing incomplete work on the Isolation Condenser piping  ;

anubber attachment welds, resulting in several welds being left undone.

The contractor in question: 1) was a reputable contractor; 2) performed S work under the contractor organization's Quality Assurance Program which met-the requirements of 10 CFR 50 Appendix B; 3) was experienced in the type of. work scope assign'ed; and 4) was appropriately qualified. However, the contractor's site management failed to assure the programmatic

. implementation of all . aspects of the work scope.

Based on this occurrence, GPU Nuclear has recognized the need to further strengthen the administrative controls'specified in several areas dealing

.with' contractor performance on site. The following corrective actions have been completed:

1. Unescorted site access to OC and TMI har been denied to the specific contractor QA Supervisor and Project Manager who were controlling the project in 1984 and who improperly certified project completion.

2. An interview process for prospective contractors being considered for key positions has been implemented.

._To preclude the recurrence of a similar event, the following corrective actions'will be completed as specified:

1. Use of the contractor QA program has been placed on restrictive

. status pending determination and implementacion of corrective actions, and verification of effectiveness of subject actions.

Restrictive status constitutes increased surveillance and oversight by GPUN QA. This action is ongoing and is an interim measure which will be rescinded only when the corrective actions have been determined by GPUN to be complete.

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, 2. The GPUN QA review process of the completed-job work packages will

-be evaluated and upgraded if necessary. The evaluation will start efter the 11R outage, and -is presently projected for completion by 2Aprili1, 1987.

3. Depending on safety significance and complexity of work, a graduated level of surveillance and oversight by GPUN QA of ,

contractor QA operations and contractor performance records has been' initiated and will be reviewed and updated if necessary.- The

-process will be reviewed after theillR outage, and is presently

= projected for . completion by April.1,1987.

4.; _GPUN will reemphasize to its supervisors and managers the

, - appropriate methods of identifying and issuing contractor work scope.- A draft instruction will be prepared after the llR outage, and is presently projected for issuance by- April 1,1987.

. 5. - GPUN will issue a procedure which will address the control of contractor work on site. The draf t of the procedure will be

-written after'the 11R outage.- The issuance of the approved procedure is presently projected for July 1, 1987.

6. The process of reviewing prospective contractor QA/QG qualifications and certifications will be reviewed and updated if necessary.~ Action will counnence af ter the llR outage, and is presently projected for completion by April 1,1987.

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