ML20216J018

Notice of Violation from Insp on 971229-980208.Violation Noted:Written SE Was Not Performed to Provide Bases for Determination That Change in Facility as Described in SAR Did Not Involve USQ

ML20216J018
Person / Time
Site:	Oyster Creek
Issue date:	04/14/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20216J005	List: ML20216H999 ML20216J018
References
50-219-97-11, EA-98-049, EA-98-49, NUDOCS 9804210282
Download: ML20216J018 (15)

Text

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ENCLOSURE NOTICE OF VIOLATION 1

r GPU Nuclear incorporated Docket No. 50 219 I Oyster Creek Nuclear Generating Station License No. DPR-16 EA 98-049 During an NRC inspection conducted from December 29,1997 through February 8,1998, l for which an exit meeting was held on February 13,1998, a violation of NRC requirements l was identified. In accordance with the " General Statement of Policy and Procedure for l NRC Enforcement Actions," NUREG 1600, the violation is set forth below:

I 1. Title 10, Code of Federal Regulations, Part 50.59, " Changes, Tests, and Experiments," (10 CFR 50.59), Section (a)(1) requires, in part, that licensees may

, make changes in the facility as described in the safaty analysis report without prior l

NRC approval, unless the proposed change involves an unreviewed safety question.

Section (b)(1) of 10 CFR 50.59 requires, in part, that licensee's records of changes in the facility must include a written safety evaluation which provides the bases for l the determination that the change does not involve an unreviewed safety question l (USO).

) Contrary to the above, a written safety evaluation was not performed to provide the l bases for the determination that a change in the facility as described in the safety l analysis report did not involve a USQ. Specifically, on January 15,1997, the l licensee changed the primary containment configuration as described in the safety l analysis report, by using a freeze seal as the primary containment boundary to l replace a degraded containment spray heat exchanger relief valve, without

! performing an associated written safety evaluation. In addition, this change, that l was made without prior NRC approval, resulted in a USQ due to the possibility of l creating an accident or malfunction of a different type than any previously evaluated in the UFSAR. ,

This is a Severity Level IV violation (Supplement 1).

l Pursuant to the provisions of 10 CFR 2.201, GPU Nuclear incorporated (Licensee) is hereby i required to submit a written statement or explanation to the U.S. Nuclear Regulatory

! Commission, ATTN: Document Control Desk, Washington, D.C. 20555, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region I, and a copy to the NRC Senior Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each j alleged violation: (1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, and if denied, the reasons why, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps that will be taken to avoid further violations, and (5) the date when full compliance will be achieved. Your response may reference or include previously docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is nor received within the time specified in this Notice, an Crder er a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked or why such other action as 9804210282 980414 PDR ADOCK 05000219 1 0 PDR .2 i _ _ _ _ _ _ _ _ _ _ _ _

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Enclosure 2 l

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[ as may be proper should not be taken. Consideration may be given to extending the  !

l response time for good cause shown. )

If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555 0001.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR. If redactions are required, a proprietary version containing brackets placed around the proprietary, privacy, and/or safeguards information should be submitted. In addition, a non proprietary version with the information in the brackets redacted should be submitted to be placed in the PDR.

l Dated at King of Prussia, Pennsylvania l this 14th day of April 1998.

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l Nuclear Regulatory Commission l Pre-Decisional Enforcement Conference 1

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1 l Oyster Creek Containment Spray Relief Valve l Replacement l

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Region I March 23,1998

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i AGENDA j

l Introduction -.

Michael Roche  ;

Director, Oyster Creek .,

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Operator Actions, Kevin Mulligan l Time Line Plant Operations Director i l

l Maintenance, Planning John Perry i Actions Plant Maintenance Director l

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Safety Significance, George Busch Mitigating Factors Manager, Nuclear Safety and l Licensing l

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Oyster Creek Containment Spray Relief Valve  !

Replacement l

Personnel Responded Promptly and Appropriately to Leaking Valve l

Isolating System, Closing Manual Valves and Gagging the Relief Valve Assured Primary Containment Integrity Decision to Replace Valve Rather Than Leave It In Gagged State Was Conservative l System Configuration Restored Temporary Modification Eliminated A Safety Review Was Not Performed as Required for the i Freeze Seal SE Completed Immediately Upon Discovery No USQs Involved i

Viewed as Significant Occurrence - Comprehensive Review and Corrective Actions Taken; Concluded the Event Was Not  !

Indicative of Programmatic Weakness in the Safety Review )

l Process. j 1

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. Sequence of Events January 15.1998 i

1012 Commenced surveillance procedure 607.4.008, Containment Spray and Emergency Service Water Pump System 2 Operability Test.

1100 Received report of water on 23' Reactor Building Elevation. Instructed the Reactor 1 Building Equipment Operator to investigate the l source of the leakage.

1105 Informed by Reactor Building Equipment Operator that Containment Spray Heat i Exchanger 1-3 Relief Valve V-21-23 is leaking

@ l-2 gpm. Notified the Containment Spray  !

System Engineer.

! Note: In an effort to stop the leakage, the operators appropriately attempted to cycle the relief l valve. As a result of participating in the PRG l Review of a previous incident, the Control Room SRO knew that leakage from this valve would have minimal effect on off site dose.

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l 1135 Secured Containment Spray and Emergency Service Water pumps.

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I150 Declared Containment Spray and Emergency l Service Water System 2 Inoperable. Entered 7 l day Technical Specification LCO in accordance l with T.S. 3.4.3.c 1235 Manually closed Containment Spray Isolation Valves V-21-13, V-21-1, and V-21-3 and de-energi7ed their respective breakers.

i Note: When these valves were closed the leakage essentially stopped. At this point the technical specification requirements for primary containment were satisfied. The SRO recognized that the isolation valves are not leak r te tested.

1325 Verified Containment Spray and Emergency Service Water System 1 operable in accordance with Procedure 106, Conduct of Operations.

Installed gag on Containment Spray Heat Exchanger 1-3 ReliefValve V-21-23.

Note: This gag was originally installed and controlled l using an outage as permitted by Procedure 108, l Equipment Control. Leakage was completely stopped. At this time, primary containment integrity was assured.

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l DISCUSSION: -

1 LCO Nntries Temporary Modification e Safety Determination e PMT e Removal Requirements l

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l. Mairatenance/ Planning Events l

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1 January 15.1998 l

l 1200 Planning requested to develop Job Order (Work Controlling Document) to replace V-21-23 Planning initiated Work Request and assigned Planner i

Selected Planner was highly experienced with l application of freeze seals.

Planner notified System Engineer and Maintenance 1430 Job Order created e Job Order calls for application of a freeze seal in accordance with OC Maintenance Procedure 2400-GMM-3921.51

+ Procedure 2400-GMM-3921.51, l Section 4.0, includes 23 prerequisites i Prerequisite 4.3 states, "a 50.59 determination has been perfonned for this specific freeze seal application and attached to the Job Order."

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+ Prerequisite 4.9 states, "the Job Planner shall consider through the Safety Review process (50,59) the additional prerequisites / precautions needed to ensure that a failed freeze plug will not impact nuclear safety, personnel safety, or equipment. The Planner shall

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include additionaljob specific prerequisites / precautions in the Job Order as applicable and shall consider the following as a minimum:..."

e Job specific prerequisites:

+ Contact RadCon prior to the start of work l

+ Class 'B' cleanliness shall be in effect I

e General prerequisites include:

' J l + The prerequisites of Procedure 2400-GMM-3921.51 have been met (freeze l seal) e Post Maintenance Testing Requirements t

l 1600 Job Order is released to the field Maintenance Technical Review performed Job Supervisor accepts Job Order for work in the field 1948 CO2 injected 2000 Freeze Seal established, defective valve replaced Note: Some "as-found" data was lost related to the manner in which the flanged connection was disassembled. This was due to insufficient clearances and lack of guidance regarding  !

specialized tooling in the Job Order.

2016 CO2injection secured l

Post Freeze Seal NDE completed Operations notified valve replacement complete Successful PMT documented concurrent with the l surveillance performed by Operations.

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< 1 l ROOT CAUSE I

I A. Contrary to the requirements listed in OC Procedure 2400-GMM-3921.51, Seetion 4.3, a 50.59 l l determination was not completed as required.

The root cause of this failure was attributed to '

human performance deficiencies, specifically the l planner's failure to apply sufficient attention to l l detail and self-checking techniques. l 1  ;

l l B. Contrary to management expectations and procedural guidance, the job supervisor failed to comply with the l prerequisites, the precautions and limitations in the l work controlling document (Job Order) and j maintenance procedure 2400-GMM-3921.51. '

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l The root cause of this failure was attributed to human performance deficiencies, specifically the job supervisor's failure to apply sufficient

, attention to detail and self-checking techniques.

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CORRECTIVE ACTIONS The Responsible Individuals Were Subject To l Disciplinary Action l

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The Incident Was Reviewed With All Planners and l Mechanical Msintenance Job Supervisors 1

i The Incident Was Reviewed In All Maintenance Shops  !

To Highlight The Need To Apply The Sufficient Level Of I l Detail To Job Order Reviews And To Fully Comply With All Job Prerequisites, Precautions And Limitations. l l

l The Incident Was Reviewed With All Operations l Personnel To Reinforce Management's Expectations Concerning Attention To Detail And Accuracy In Log Keeping.

l Human Performance Eye Opener Issued i r

Will Perform Barrier Analysis to Determine Barrier Effectiveness

l SAFETY SIGNIFICANCE l Valve Leakage Was Low (Approximately 2 gpm)

. System Was Isolated and Valves De-energized l e Valve Was Gagged Within 2,5 Hours e Leakage completely stopped when gagged. j e Replacement decision PMT not required Analysis of Similar Valve (LER 96-4) e Leakage of 20 gpm well below Part 100 Limit

. DBA LOCA With Valve Open Would Have Negligible Offsite Dose Consequences No SD/SE for freeze seal (violation of procedure and 50.59)

Subsequent SE results determined:

1 e No unreviewed Safety Questions )

e No Technical Specification changes required i

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MITIGATING FACTORS Proactively Replaced Valve to Eliminate Temporary Modification Experienced PersonnelInvolved:

Operations, System Engineer, Planning Safety Issues Fully Discussed Timely, Comprehensive Corrective Actions Taken

• Safety Evaluation Completed

. Event Review Initiated e PERC Review Conducted with Involved Personnel e Process Review to Identify Barrier Effectiveness