ML20214W366

Responds to NRC Re Violations Noted in Insp Rept 50-219/87-08.Corrective Actions:Identified Procedure Will Be Issued Prior to Next Scheduled Surveillance

ML20214W366
Person / Time
Site:	Oyster Creek
Issue date:	06/01/1987
From:	Fiedler P GENERAL PUBLIC UTILITIES CORP.
To:	Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8706150231
Download: ML20214W366 (3)

Text

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b O GPU Nuclear Corporation NggIg{ Post Office Box 388 Route 9 South Forked River.New Jersey 08731-0388 609 971-4000 Writers Direct Dial Number:

June 1,1987 Samual J. Collins, Deputy Director Division of Reactor Projects U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406

Subject:

Oyster Creek Nuclear Generating Station Docket No. 50-219 IE Inspection report 50-219/87-08 Response to Notice of Violation Attachment I to this letter provides GPU Nuclear's response to the Notice of Violation in Appendix A to your letter dated May 1,1987. If any further information is required, please contact Mr. Michael Heller of my staff at (609)971-4680.

rytrlyyouth j n m 8706150231 870601 PDR ADOCM 05000219

!e O PDR e :er B. Fiedl Vi:e Presiden nd Dir M or M

0 st'er Creek l

l l PBF/MH/dmd ch nt cer;Mr.~ William T.c Russell,IAdministrator ' #

l Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 l

Mr. Alexander W. Dromerick, Project Manager l

U.S. Nuclear Regulatory Commission Division of Reactor Projects I/II 7920 Norfolk Avenue, Phillips Bldg.

Bethesda, MD 20014 l

Mail Stop No. 316 l NRC Resident Inspector l

Oyster Creek Nuclear Generating Station Forked River, NJ 08731

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GPU Nuc: ear Ccrporation is a subsidiary of the General Pubhc Utihties Corporation IT-O\

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ATTACHMENT I Violation:

Technical Specification 6.8.1 states, " Written procedures shall be established, implemented, and maintained that meet or exceed the requirements of the Nuclear Regulatory Commission's Regulatory Guide 1.33..." Appendix A of Regulatory Guide 1.33 states that, " Specific procedures for surveillance... calibrations should be written (implementing procedures are required for each... calibration listed in the Technical Specifications)."

Contrary to the above, as of March 12, 1987 and during a calibration performed in July 1986 no implementing procedure had been prepared for the calibration of the primary containment sump flow integrator and the primary containment equipment drain tank flow integrator listed in Technical Specification 4.3.H.

Response

GPUN accepts the NRC's position on the violation.

Normal use and routine calibration of the primary containment sump flow integrater have been accomplished at the Oyster Creek Nuclear Generating Station since original construction. The maintenance of this device was always previously controlled by Station Procedure 112.1, Attachment I,

" Technical Specification Supporting Installed Instrumentation List".

Operating License DPR-16 Amendment 97, issued January 6,1986 and corrected January 28, 1986, included the requirement to calibrate the primary containment sump flow integrator at least once every eighteen months. During the work prioritization activity, the task of writing a separate surveillance procedure to accomplish this calibration was acknowledged, but assigned a low priority as it was determined that the existing procedure was sufficient to meet Technical Specification requirements. The surveillance was added to the Master Surveillance Schedule in accordance with the requirements of the revised Technical Specification.

The calibration was performed as scheduled. An out of calibration I

condition was noted,and the appropriate deficiency paperwork initiated.

Corrective maintenance was performed as required and a successful calibration completed.

Regulatory Guide 1.33, Revision 2-February 1978, (os committed to in the GPUN Quality Assurance Plan) endorsed ANSI 18.7-1976. ANSI 18.7-1976

, Section 5.2.8 specifies the purpose of the surveillance testing program to ensure:

"... safety related structures, systems, and components will continue to operate, keeping parameters within normal bands, or will act to l place the plant in a safe condition if they exceed nonnal bounds."

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.: 1 The guidance given in Regulatory Guide 1.33-February 1978, Appendix A, section 8.b states:

"Spectfic procedures for surveillance tests, including inspections and calibrations should be written (implementing procedures are required for each surveillance, test, inspection, or calibration listed in the technical specifications) .. ."

While GPUN acknowledges that this occurrence was not in complete compliance with the parenthetic phrase contained in Appendix A to Regulatory Guide 1.33, GPUN states that the intent of the surveillance procedure was fulfilled. The adequacy of the calibration procedure and administrative controls were never in question, as evidenced by the issuance of the deficiency paperwork and timely corrective action.

Imediate corrective action was taken to assure that the identified procedure will be issued prior to the next scheduled surveillance.

To preclude a recurrence of th.s evant, this LER will be placed in required reading for those personnel responsible for initiating and revising surveillance procedures. Full compliance will be achieved with the completion of the required reading before the end of the second.

quarter 1987, and with the issuance of the identified procedure, scheduled for performance during Refueling Outage 12R.

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