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Forwards Insp Rept 50-219/98-80 on 980223-0313 & 0330-0402 & Notice of Violation.Insp Consisted of Safety Sys Engineering Insp Focusing on ADS & Css.Open Predecisional Enforcement Conference Scheduled for 980529 to Discuss Violations
	ML20217F627
Person / Time
Site:	Oyster Creek
Issue date:	04/22/1998
From:	Wiggins J; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Roche M; GENERAL PUBLIC UTILITIES CORP.
Shared Package
ML20217F631	List: ML20217F627; ML20217F649; ML20217F664;
References
	50-219-98-80, EA-98-187, EA-98-220, NUDOCS 9804280210
	Download: ML20217F627 (7)
	v • d • e

April 22, 1998

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EA Nos:

98-187

98 220

Mr. Michael B. Roche

Vice President and Director

GPU Nuclear incorporated

Oyster Creek Nuclear Generating Station

P.O. Box 388

Forked River, New Jersey 08731

SUBJECT: NOTICE OF VIOLATION AND NRC ENGINEERING TEAM INSPECTION REPORT

NO. 50-219/98-80

Dear Mr. Roche:

This refers to the engineering team inspection conducted on February 23 to April 2,1998,

at your Oyster Creek Nuclear Generating Station. The inspection consisted of a safety

system engineering inspection (SSEI) focusing on the automatic depressurization system

(ADS) and the containment spray system (CSS); and evaluation of the safety evaluation

and corrective action r ograms. The enclosed report presents the results of this

'

inspection. The results were initially discussed with you, Mr. Art Rone, and others of your

staff at an exit meeting held on March 20,1998. Subsequent to that meeting, we

conducted further inspection on March 30, to April 2,1998, of your activities surrounding

the ADS valves. The results of the follow up inspection were discussed, via a telephone

conference, call with Messrs. S. Levin, D. Slear, and others of your staff on April 8,

1998.

Based on the results of this inspections, four violations of NRC requirements were

identified. These four violations are cited in the enclosed Notice of Violation (Notice) and

the circumstances surrounding them are described in the subject inspection report. The

,

violations are of concern because they were identified by the NRC and two of them

involved safety related systems that are essential for mitigating the consequences of

design basis accidents involving the reactor coolant pressure boundary or the containment.

These violations involved: (1) Failure to adhere to the requirement of Technical Specification 3.4.B.1 to maintain the five EMRVs operable during the reactor vessel

pressure test on October 6,1996;(2) Two instances of failure to adhere to 10 CFR 50,

Appendix B, Criterion V, instructions, Procedures, and Drawings, to follow established

procedures that control activities affecting quality; (3) Failure to adhere to 10 CFR 50,

Appendix B, Criterion XVI, Corrective Actions, to adequately correct a seismic deficiency

with a containment spray heat exchanger; and (4) Failure to adhere to 10 CFR 50.59,

changes, tests and experiments, to submit report summaries of plant changes, tests and

experiments. Reparding these four violations, you are required to respond and follow the

instructions specified in the Notice of Violation when preparing your response. The NRC

will use your response, in part, to determine whether further enforcement action is

necessary to ensure compliance with regulatory requirements.

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Mr. Michael B. Roche

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Finally,3 apparent violations were identified and are being considered for escalated

enforcement action in accordance with the " General Statement of Policy and Procedure for

NRC Enforcement Actions" (Enforcement Policy), NUREG-1600. The three apparent

violatic,ns involve the inability of three of the ADS electromatic relief valves (EMRV)

solenoids to function under certain design basis ar.cident condition thereby rendering the

ADS inoperable. Specifically: (1) Failure of your engineering design control measures to

ensure the adequacy of the voltage required for the EMRV solenoids to function during a

postulated small break loss of coolant accident (SBLOCA), concurrent with a loss of offsite

power (LOOP) and a worst case single failure. This is an apparent violation of 10 CFR 50,

Appendix B, Criterion Ill, Design Control; (2) Failure to verify that the EMRV solenoid

voltage was in accordance with the environmental qualification (EO) documentation. This

is an apparent violation of 10 CFR 50.49, Environmental Qualification; and (3) Failure to

maintain the ADS operable as of March 19,1998, when it was not capable of performing

its required function in the above scenario. This is an apparent violation of Technical Specification 3.4.B.1, ADS, which requires the five EMRVs to be operable when reactor

water temperature is greater than 212 *F and pressurized above 110 psig. Accordingly,

no Notice of Violation is presently being issued for these inspection findings, in addition,

please be advised that the number and characterization of apparent violations described in

the enclosed inspection report may change as a result of further NRC review.

An open predecisional enforcement conference to discuss these apparent violations has

been scheduled for Friday, May 29,1998. The decision to hold a predecisional

enforcement conference does not mean that the NRC has determined that a violation has

occurred or that enforcement action will be taken. This conference is being held to obtain

information to enable the NRC to make an enforcement decision, such as a common

understanding of the facts, root causes, missed opportunities to identify the apparent

violation sooner, corrective actions, significance of the issues and the need for lasting and

effective corrective action. In particular, we expect you to address how your staff failed to

identify these discrepancies earlier, especially during their reviews of the system as part of

various programmatic upgrade efforts (e.g 10 CFR 50.54f response; design basis

,

document reviews; and environmental qualification efforts). Also, be prepared to address

your current reviews and understanding of the extent of the condition. In addition, this is

an opportunity for you to point out any errors in our inspection report and for you to

provide any information concerning your perspectives on 1) the severity of the violation (s),

l

2) the application of the factors that the NRC considers when it determines the amount of

l

a civil penalty that may be assessed in accordance with Section VI.B.2 of the Enforcement

Policy, and 3) any other application of the Enforcement Policy to this case, including the

exercise of discretion in accordance with Section Vll.

l

You will be advised by separate correspondence of the results of our deliberations on this

matter. No response regarding these apparent violations is required at this time.

Overall, our inspectors observed that, apart from the issues discussed above, the ADS and

CSS were maintained well by knowledgeable and technically competent engineering

personnel. System modifications were properly implemented, and surveillance test criteria

were consistent with the design basis. The CSS, as well as it's support systems, was

maintained operable and capable of performing it's intended safety function.

1

1.

.

- -

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.

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.

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Mr. Michael B. Roche

3

in the programmatic areas, the 10 CFR 50.59, Safety Evaluation Program was being

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implemented well. Procedures were comprehensive and detailed, and safety evaluations

were prepared and reviewed by qualified personnel and in accordance with the requirement

of 10 CFR 50.59. The Corrective Action Program was also being implemented well.

Deviation Reports were of good quality and contained appropriate management reviews.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this latter

and its enclosure will be placed in the NRC Public Document Room.

1

Sincerely,

]

James T. Wiggins, Director

Division of Reactor Safety

Docket No.

50-219

License No.

DPR-16

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72-1004

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Enclosures:

1. Notice of Violation

2. NRC Inspection Report No. 50-219/98-80

cc w/enci:

G. Busch, Manager, Nuclear Safety & Licensing

M. Laggart, Manager, Licensing & Vendor Audits

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State of New Jersey

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Mr. Michael B. Roche

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Distribution w/ encl:

Region i Docket Room (with concurrences)

. Nuclear Safety information Center (NSIC)

NRC Resident inspector

PUBLIC

H. Miller, RA

J. Wiggins, DRS

N. Perry, DRP

M. Evans, DRP

D. Haverkamp, DRP

J. Yerokun, DRS

A. Linde, DRP

R. Eaton, NRR/PD l-3 -

OE (2)

T. Elsasser, Contractor

DOCDESK

Inspection Program Branch, NRR (IPAS)

Distribution w/enci (VIA E-MAIL):

B. McCabe, OEDO

P. Milano, NRR/PD l-3

C. Thomas, NRR/PD 1-3

R. Correia, NRR

F. Talbot, NRR

DOCDESK

Inspection Program Branch, NRR (IPAS)

DOCUMENT NAME: G:\\ SYSTEMS \\YEROKUN\\OC9880.lNS

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April 22, 1998

EA Nos:

98-187

98-220

Mr. Michael B. Roche

Vice President and Director

GPU Nuclear incorporated

Oyster Creek Nuclear Generating Station

P.O. Box 388

i

Forked River, New Jersey 08731

1

'

SUBJECT: NOTICE OF VIOLATION AND NRC ENGINEERING TEAM INSPECTION REPORT

l

NO. 50-219/98 80

Dear Mr. Roche:

l

This refers to the engineering team inspection conducted on February 23 to April 2,1998,

j

at your Oyster Creek Nuclear Generating Station. The inspection consisted of a safety

l

system engineering inspection (SSEI) focusing on the automatic depressurization system

l

(ADS) and the containment spray system (CSS); and evaluation of the safety evaluation

and corrective action programs. The enclosed report presents the results of this

inspection. The results were initially discussed with you, Mr. Art Rone, and others of your

staff at an exit meeting held on March 20,1998. Subsequent to that meeting, we

l

conducted further inspection on March 30, to April 2,1998, of your activities surrounding

'

the ADS valves. The results of the follow up inspection were discussed, via a telephone

l

conference, call with Messrs. S. Levin, D. Slear, and others of your staff on April 8,

!

1998.

!

l

Based on the results of this inspections, four violations of NRC requirements were

l

identified. These four violations are cited in the enclosed Notice of Violation (Notice) and

l

the circumstances surrounding them are described in the subject inspection report. The

i

violations are of concern because they were identified by the NRC and two of them

l

involved safety related systems that are essential for mitigating the consequences of

design basis accidents involving the reactor coolant pressure boundary or the containment.

l

These violations involved: (1) Failure to adhere to the requirement of Technical Specification 3.4.B.1 to maintain the five EMRVs operable during the reactor vessel

pressure test on October 6,1996;(2) Two instances of failure to adhere to 10 CFR 50,

Appendix B, Criterion V, instructions, Procedures, and Drawings, to follow established

procedures that control activities affecting quality; (3) Failure to adhere to 10 CFR 50,

Appendix B, Criterion XVI, Corrective Actions, to adequately correct a seismic deficiency

with a containment spray heat exchanger; and (4) Failure to adhere to 10 CFR 50.59,

changes, tests and experiments, to submit report summaries of plant changes, tests and

experiments. Regarding these four violations, you are required to respond and follow the

instructions specified in the Notice of Violation when preparing your response. The NRC

'

will use your response, in part, to determine whether further enforcement actiun is

necessary to ensure compliance with regulatory requirements.

i

.

..

.

. _ _ _ -

- _ _ _ - _ - _ _

___

__ ___

.

Mr. Michael B. Roche

2

Finally,3 apparent violations were identified and are being considered for escalated

enforcement action in accordance with the " General Statement of Policy and Procedure for

NRC Enforcement Actions" (Enforcement Policy), NUREG-1600. The three apparent

violations involve the inability of three of the ADS electromatic relief valves (EMRV)

solenoids to function under certain design basis accident condition thereby rendering the

ADS inoperable. Specifically: (1) Failure of your engineering design control measures to

ensure the adequacy of the voltage required for the EMRV solenoids to function during a

postulated small break loss of coolant accident (SBLOCA), concurrent with a loss of offsite

power (LOOP) and a worst case single failure. This is an apparent violation of 10 CFR 50;

Appendix B, Criterion Ill, Design Control; (2) Failure to verify that the EMRV solenoid

voltage was in accordance with the environmental qualification (EQ) documentation. This

is an apparent violation of 10 CFR 50.49, Environmental Qualification; and (3) Failure to

maintain the ADS operable as of March 19,1998, when it was not capable of performing

its required function in the above scenario. This is an apparent violation of Technical Specification 3.4.B.1, ADS, which requires the five EMRVs to be operable when reactor

water temperature is greater than 212 *F and pressurized above 110 psig. Accordingly,

no Notice of Violation is presently being issued for these inspection findings, in addition,

please be advised that the r. umber and characterization of apparent violations described in