ML20207J745
| ML20207J745 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 09/16/1988 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Fitzpatrick E GENERAL PUBLIC UTILITIES CORP. |
| References | |
| EA-88-203, NUDOCS 8809280103 | |
| Download: ML20207J745 (5) | |
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0 SEP 161988 Docket No. 50-219 EA 88-203 GPU Nuclear Corporation ATTN: Mr. Eugene E. Fitzpatrick Vice President and Director Oyster Creek Nuclear Generating Station P. O. Box 388
{
Forked River, NJ 08731 I
Gentlemen:
Sul; ject:
Enforcement Conference On August 2, 1988, we sent you a letter informing you of our plans to conduct an enforcement conference with you to discuss certain potential violations relating to equipment qualification issues identified during an inspection in March 1986. Although that conference was originally scheduled for August 30,-
i 1988, that conference was postponed.
This letter is to inform you that the t
en' rcement conference v4'1 be rescheduled within 30 days, j
In addition to the itec et forth in the August 2, 1988 letter, you should also be prepared to discuss at the enforcement conference (1) another deficiency involving the envi mmental qualification of Stanwick terminal blocks located i
in the RE-23 TB enclosure at Oyster Creek, which was initially raisert with your staff by the NRC during the period December 2-6, 1985 and which is discussed in NRC Inspection Report No. 50-219/85-39 sent to you on February 14, 1986; and, I
(2) the findings of an investigation by the NRC Office of Investigation (01)
}
concerning the accuracy and completeness of information provided to the NF.'
during a December 5, 1985 conference call between GPUN and NRC personnel l
concerning the identity and equipment qualification status of terminal blocks located in the RE-23 TB enclosures. The O! synopsis is enclosed.
j t
With respect to the findings of the 0! investigation as well as NRC Inspection No. 3-219/85-39 concerning the Stanwick terminal blocks, you should be prepared to discuss the following:
1.
The extent of EQ walkdowns prior to November 30, 1985 for terminal block l
i identification; j
l 2.
The basis for the statement made by the GPUN manager of Equipment Qualification on December 5,1985 that only three types of qualified i
blocks (General Electric, States or Weidmuller) were used at Oyster Creek, when in fact four Stanwick blocks were also used.
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t I
l 0FFICIAL RECORD COPY ANDERSON 9/8/88 - 0001.0.0 g g l
09/14/88 8809280103 880916 TE*O) l PDR ADOCK 05000219 0
SEP 161938 GPU Nuclear Corporation 2
3.
The basis for your staf f's conclusion on December 5,1985 that Weidr.uller terminal blocks were qualified despite known deficiencies in the enclo-sures (terminal boxes), considering the fact that the Weidmuller blocks were qualified with a terminal box (NEMA-4) test configuration.
Thank you for your cooperation in this matter.
Sincerely, O!i'0!i1M. Sici!ED BY Mt!AM V. J0hhSION
- Thomas T. Martin, Director
/
Division of Reactor Safety
Enclosure:
Office of Investigation Report Synopsis No.1-87-V06 cc w/ enc 1:
M. Laggart, BWR Licensing Manager Licensing Manager, Oyster Creek Public Document Room (PDR) local Public Document Room (cPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of New Jersey bec w/enr.1:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o encl)
Section Chief, DRP C. Stahl, PM, NRR Robert J. Bores, ORSS RI:D R D R
R Anderson Du Martin 9//2/88 A*7 8 9//) /88 i
0FFICIAL RECORD COPY ANDERSON 9/8/88 - 0001.1.0 09/09/88
'.".M22.C& @LG 5YNOPSIS This investigation was self-initiated by the Director, Office of Investigations (0!) Field Office, Region I, on May 8, 1987, to determine if General Public Utilities Nuclear (GPUN), willfully misinformed the NRC concerning the status of their Environmental Qualification (EQ) program at the Oyster Creek Nuclear Generating Station (OCNGS) during a conference call on December 5, 1985.
OCNGS is a 650 MWe Boiling Water Reactor (BWR) located in Ocean County, New Jersey.
It was licensed by the NRC on August 1, 1969.
On January 14, 1980, the NRC issued IE Bulletin (IEB)79-01B, with attached Division of Operating Reactor (DOR) Guidelines and NUREG-0588.
Subsequently, on May 23, 1980, a Commission Memorandum containing Order CLI-80-21 was issued and stated that the D0R Guideline' and NUREG-0588 form the basis of the requirements that licensees must meet regarding the EQ of safety-related electrical equipment.
The "final rule," 10 CFR 50.49, became effective on February 23, 1983.
This rule specifies the requirements to be met fo-demon-strating the EQ of electrical equipment important to safety located in areas that could be subjected to harsh environments resulting from design basis accidents.
It further established the date of November 30,1985, as the qualification deadline, and identified the "Commission itself" as the approval level for the granting of extensions beyond the deadline.
On August 6, 1985, the NRC issued Generic letter (GL) 85-15 (dated August 6, 1985) to all licensees of operating reactors informing them that the Comission would grant extensions "only in rare circumstances and that enforcement action will be taken against licensees that continue to operate their plants with unqualified equipment beyond November 30, 1985, without extensions appro,ad by the Comission." The letter emphasized that "unqualified equipment" meant equipment for which there was inadequate documentation to support qualification.
By letter dated November 26, 1985, GPUN advised the NRC that "... adequate inspection has been perfonned to provide reasonable assurance that Oyster Creek meets the requ,irements of 10 CFR 50.49."
Testimony and documentary evidence show that on November 26, 1985, four terminal boxes that housed tenninal blocks (E control circuit of pressure switches RE-23(A)Q, components) utilized in the(B), (C) to have certain deficiencies that could impact on the qualification of the enclosed tenninal blocks (tbs).
At OCNGS, tbs were environmentally qualified as "comon items" and not provided with a tag number as was done with valves, transmitters, s.d tches, etc.
The identity of "comon items" was determined by reviewing maintenance records, installation records, modification records, and by conducting a sampling of field walkdowns.
Based on this process, the GPUN Manager of EQ determined that OCNGS was utilizing one of three (General Electric (GE), States, or Weidmuller) manufactured tbs for RE-23 application.
The GPUN Manager of EQ was advised of the tenninal box deficiencies on Wednesday afternoon, November 27, 1985, and was of the ur.derstanding that the deficiencies would be corrected prior to the November 30, 1985, EQ deadline.
He testified that he did not evaluate the deficiencies to determine if they represented a Case No.
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qu611fication/ operability issue even though he was requested to do so by the OCNGS Safety Review Manager (SRM).
He indicated that it was GPUN's that such matters would be reviewed in a "prudent and timely manner"policy and he informed the OCNGS SRM that he would get "back to him" the following week (after the long Thanksgiving Day weekend).
On Monday, December 2, 1985, the GPUN Nanager of EQ learned that the tenninal box deficiencies were not corrected as requested or the maintenance requests.
GPUN maintenance documentation indicates that the terminal box deficiencies were not corrected until Tuesday afternoon, December 3,1985. As of November 30, 1985, OCNGS EQ documentation reflected three types (manufacturers) of tbs that could have been in use for RE-23 application, i.e., States, GE, or Weidmuller.
Testimony and documentary evidence indicates that there was no attempt to specifically identify which type of TB was a".tually in place.
OCNGS EQ files represent the Weidmuller TB as being qualified with a terminal box (NEMA-4) test configuration, whereas both the GE and States tbs were qualified without a terminal box.
Testimony and documentary evidence established that States tbs were not discovered to be in use at OCNGS until The August - October, 1985 time period when they were identified during a "walkdown" of GE motor control centers.
The GPUN Manager of EQ and the EQ Manager both testified that between December 2 and 4,1985, they, along with the OCNGS EQ Engineer, conducted an undocumented review of the terminal box deficiencies as they may have related to GE, States, and/or Weidmuller tbs. All three types of tbs were considered because it was not known which type of TB was actually in place for RE-23 application.
The GPUN Manager of EQ testified that based on this review, it was his judgement that GE, States, and Weidmuller tbs would all be environmentally qualified despite the known deficiencies that existed with the RE-23 tenninal boxes between November 26 and December 3, 1985.
The OCNGS NRC Resident Inspectors began following GPUN's actions relating to the RE-23 terminal boxes more closely when, on December 2, 1985, they (Resident Inspectors) discovered that OCNGS had operated past November 30, 1985, with a possible EQ deficiency. On December 5, 1985, a three-way NRC-GPUN conference call was held to digcuss the matter. The GPUN Manager of EQ testified that during the conference call, he infonned the NRC that either GE, States, or Weidmuller tbs were in place for RE-23 application.
He further infonned the NRC that based upon an evaluation, any one of the three tbs were environmentally qualified despite the known deficiencies with the tenninal boxes that existed between Novem>er 26, 1985, and December 3, 1985.
Based on this information, the NRC requested the appropriate System Com)onent Evaluation Worksheet (SCEW) for a qualification review.
Consequently, tie GPUN EQ Manager directed OCNGS personnel to "walkdown" the four tbs and identify the s)ecific manufacturer so that the appropriate SCEW sheet could be forwarded to tie NRC in King of Prussia. The December 5, 1985, "walkdown" determined that Stanwick tbs were being utilized for RE-23 application, and that GPUN did not have the Stanwick tbs listed on their OCNGS EQ Master List and did not have documentation establishing qualification for compliance with 10 CFR 50.49.
Although the oral statement made by the GPUN Manager of EQ was clearly false, evidence does not support a finding that he made the false statement with a clear / demonstrable knowledge of its inaccuracy.
Additionally, a review of appropriate qualification documentation by the NRC's Plant Systems Branch Case No.
1-87-006 2
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(PSB) detennined that either GE. States, and/or Weidmoller tbs would have been environmentally qualified for RE-23 application despite the known deficiencies that existed with the RE-23 terminal boxes.
However, the PSB concluded that GPUN should have completed a 100% field "walkdown" prior to November 30, 1985, to ensure compliance with 10 CFR 50.49.
This regulation (10 CFR 50.49) required licensees to identify electrical equipment important to safety, e.g., Stanwick T8s uttitzed for RE-23 :,pplication.
Not doing a 100%
"walkdown" of coninon items such as tbs appears to have been a position taken by GPUN as demonstrated by a November 26, 1985, letter from the President of GPUN to the NRC.
The letter infonned the NRC that some types of EQ components (e.g., tenninal boxes) were identified on a sample basis and that a "100%
walkdown" was not conducted.
GL 85-15 clearly put all licensees on notice of the troortance of completing EQ prior to November 30, 1985.
The Manager of EQ testified that he was familiar with GL 85-15 and that he was asked to determine if the RE-23 terminal box deficiencies represented a qualification issue on November 27, 1985.
However, he did not review the matter until December 2-4, 1985, after discovering that the deficiencies had not been corrected prior to the EQ deadline.
The review considered only the GE, States, and Weihuller tbs (those identified on the OCNGS EQ Master List), and he did not attempt to detennine the specific identity of the RE-23 tbs until after the December 5, 1985, conference call with the NRC.
He testified that OCNGS had not done a 100% "walkdown" to identify all OCNGS tbs, and that States' tbs were not discovered to be in use until the August - October 1985 time period.
The Manager of EQ further testified that he was informed that the NRC had expressed an interest in the RE-23 issues on December 2,1985, and that the December 5,1985, conference call was initiated by the NRC to discuss issues surrounding the RE-23 pressure switches, tenninal boxes, and tbs.
It is the reporting Investigator's conclusion that GPUN provided false information with careless disregard for its accuracy and completeness to the NRC concerning the identity and EQ status of their RE-23 tbs during the December 5, 1985, conference call.
Case No.
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