ML20207T597
| ML20207T597 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 03/16/1987 |
| From: | Wilson R GENERAL PUBLIC UTILITIES CORP. |
| To: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 5000-87-1191, NUDOCS 8703240168 | |
| Download: ML20207T597 (5) | |
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GPU Nuclear Corporation Nuclear
- == 388 March 16, 1987 Forked River.New Jersey 08731-0388 5000-87-1191 609 971-4000 Writer's Direct Dial Number:
Mr. Stewart D. Ebneter, Director U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Ebneter:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 IE Inspection Report 50-219/86-37 Attachment I to this letter provides GPU Nuclear's res~ nses to the identified violations in Appendix A of your letter dated January '.2,1987.
An extension of the due date to March 18, 1987 was granted by Mr. A. R. Blough, Chief, Reactor Projects. The extension was necessitated by a GPU Nuclear field walkdown to verify the specifics of the referenced violations.
As is detailed in Attachment I, GPU Nuclear disagrees with several details of the violations, but acknowledges the conceptual content of the violations and has specified corrective actions to address these concerns.
If any further information is required, please contact Mr. John Rogers of my staff at (609)971-4893.
y druly yours, Al, w R. F.
1 son Director Technical Functions RFW/JJR/ dam (0289A)
Attachment cc:
Dr. Thomas E. Murley, Administrator Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 8703240168 870316 gDR ADOCK 05000219 PDR 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 Corporabon is a subsidiary of the General Publjhihties Corporation re -e \\
r Attachment I NRC Bases for Violations:
10 CFR 50,. Appendix B, Criterion V, requires that the activities affecting quality shall be prescribed by documented instructions, procedures, or drawings appropriate to the circumstance. 10 CFR 50, Appendix B, Criterion VI, requires that measures shall be established to control the issuance of documents such as drawings which prescribe all.
activities affecting quality. These measures shall assure that documents including changes are reviewed for adequacy, approved, and distributed to i
and used at the location where the prescribed activity is performed. GPU Operational Quality Assurance Plan 100-PLN-7200.01, Revision 1, dated November 1,1985, Section 3, paragraph 3.1.2.g, requires that changes be documented and approved prior to being implemented.
Contrary to the above, on November 21, 1985, several changes 'n the safety related electrical power systems were not documented prior to being implemented as evidenced by the fact that the following differences between the associated as-built drawings and the field installation were identified and that no other documents existed indicating these changes.
Violation A, Drawing EB-D-3033, Rev. 8 I
Item 1, (Text in Violation):
The field installation of circuit breakers in positions 5, 6, 7, 8, 13,'14 and 15 were rated 225 Amps unlike the drawing representation of 100 Amps.
Item 1, (Text in Inspection Report):
Breakers at position 5, 6, 7, 8,13,14, and 15 are indicated by Note 1 on the above drawing as rated for 100 Amps.
It was verified in the field and in the Gould Specification No. 210-77-8, Revision 0, Bill of Materials, item 4, that these breakers are rated for 225 i
Amps.
Results of GPUN Inspection, Item A.1:
On February 3,1987 GPUN opened and inspected 125V DC Distribution Center C.
The following was documented on Field Change Notice (FCN) C050004.
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Breakers in positions 3, 4, 5, 6, 7, 8, 9,10,11 and 13 are Gould-ITE Frame Catalog No. JL 2 F-400, a 400 amp frame size breaker, In breaker positions 3 and 4 200 amp thermal overloads are installed in t
the breakers.
In breaker positions 5, 6, 7, 8, 9,10,11, and 13, 70 amp thermal overloads are installed in the breakers. Positions No.12 and 14 l
are blank. There is no position 15.
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Both note 1 on the drawing and this finding are incorrect.
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Item 2 (Text in Violation):
In position 10, the 600A breaker, 500A Fuse and Cable 62-155 as shown on the drawing, do not exist in the field.
Item 2 (Text in Inspection Report):
The drawing indicates a 600A breaker and 500A fuse at position 10 supplying computer supply inverter.
Neither the breaker nor the i
fuse are installed in the field.
l Results of GPUN Inspection, Item A.2:
There is.no. feeder to the computer supply inverter in the distribution center and the finding is correct. The 600A breaker and 500A fuse do not 4
exist in the panel.
Position No.10 is occupied by a 400 amp frame size breaker with a 70 amp l
thermal overload installed.
Item 3 (Text in Violation):
f The 70A fuse shown in drawing at position 14 does not exist in the l
fiel d.
Item 3 (Text in Inspection Report):
The 70 Amp fuse at position 14 is shown as located within the 125 VDC distribution center. The team verified that this fuse is not located within the distribution center.
l Results of GPUN Inspection, Item A.3:
The 70 amp fuse at position 14 (whose correct position number has been changed to 8) does not exist in the panel. Position No.14 is a blank cover plate over an empty position.
Response to Violation A:
GPUN acknowledges the NRC's position on Violation A.
In the period since 1982, GPUN has escalated the need to promptly record and evaluate conditions discovered in the plant which differ from As-Built drawings.
Prior to 1983, the drawing Verification Program was conducted for GPU by an outside contractor. Changes to drawings were made as necessary from documentation provided by that contractor. The 125V DC Panel C was one of those verifications.
Until this inspection there had been no reason i
to suspect that 125V DC Distribution Center C was not thoroughly documented.
In 1984 GPUN replaced the outside independent contractor who was performing the verifications. Subsequently using in-house resources, GPUN has completed and documented 146 out of 163 electrical verifications. Both documentation and resulting drawing revisions have been completed in compliance with currently approved Technical Functions Procedures EP-002, EMP-015, and EP-025.
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During the year 1986, anomalies with As-Built drawings were processed at the rate of approximately thirteen As-Found FCN's (Technical Functions Procedure EMP-015) per month. To date, only one has resulted in a decision to initiate a Preliminary Safety Concern.
While these recordings have been important they did not raise serious safety issues.
The specific drawing discrepancies which were found during both the NRC inspection and the subsequent GPUN inspection were evaluated for impact on the Oyster Creek Plant.
It was determined that the anomalies do not degrade the integrity of the respective safety related buses, nor do they invalidate any electricial load or breaker coordination studies performed to date.
Immediate corrective action was initiated to commence a reverification of I
the functional devices in the identified 125 VDC Distribution Center C originally verified in 1983.
The specific discrepancies found on drawing EB-D-3033, Rev. 8 represent an isolated case and are not indicative of a progransnatic failure of the Verification Program conducted between 1983 and 1984.
To assure the accuracy of the Verification Program, a sampling of major components previously verified by the independent contractor will be re-verified.
This effort will be completed during the third quarter,1987. Any additional deviations, if identified, will be promptly documented and addressed in full accordance with approved procedures.
The function and purpose of Technical Functions procedure EMP-015 are to provide a program to control the documentation and revision of drawings where important data are not clearly shown on drawings. The Verification Program does this in critical areas. The As-Found FCNs usually do this in important but non-critical areas, but have also been utilized in critical areas, resulting in prompt revision to requisite drawings.
The effectiveness of this program is demonstrated by the initiation and processing of the aforemmtioned thirteen FCNs per month.
Full compliance will be achieved as the referenced Verification Program progresses toward completion. The As-Found portion of the drawing control program will continue after the completion of the Verification Program.
Violation B, Drawing BR 3013, Rev. 27:
Item 1:
On instrument panel 4, the field installation at positions 15,17 and 19 indicates single phase breakers, with ratings 20A, 20A and 40A, but the drawing indicates position 15 to have a single three phase supply with a 50 Amp breaker and does not indicate positions 17 and 19.
Item 2:
The field installation in instrument panel 4B at position 8,15 and 17 have blank spaces (no breakers), but the drawing indicates 20A breakers to panel 10R, panel 2F, and a spare respectively.
Responsa to Violation B:
GPUN does not concur in the violation.
While it is acknowledged that the conditions described in the violation did exist 6t the time of the inspection, Panel 4 and 4B were in the process of modification.
Subsequent to the inspection, the identified modifications were completed, the system responsibility turnover from maintenance to operations occurred, and the requisite revisions to the appropriate As-Built drawings were issued in accordance with Technical Functions procedures.
Additional non-conformances were identified in the text of IE Inspection Report 50-219/86-37, but were not included in the violation specifics detailed in Apsandix A of that report. GPU Nuclear included these additional specifics in the field walkdown, and the results of that walkdown are on file and available for NRC review.
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