ML20235E037
| ML20235E037 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 09/04/1987 |
| From: | Fiedler P GENERAL PUBLIC UTILITIES CORP. |
| To: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8709250460 | |
| Download: ML20235E037 (5) | |
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USNRC-05
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1981 SEP 25 A 9 44 Route 9 South Post Office Box 388 Forked River,New Jersey 08731-0388 609 971-4000 Writers Direct Dial Number:
September 4, 1987 Samuel 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 l
Docket No. 50-219 IE Inspection Report 50-219/87-13 Response to Notices of Violation The Attachment to this letter provides GPU Nuclear's response to the Notices of Violation in Appendix A to your letter dated July 10, 1987.
An extension of the due date to September 4,1987 was granted by Mr.
P,. Blough of your staff on August 28, 1987.
If any further information is required, please contact Mr. John Rogers of my staff at (609)971-4893.
Very truly yours, p n)
Kr W P6tM. n ew(er _ _
Vice President and Director Oyster Creek l
PDF/JR/dmd (0358A)
Attachment j
cc: Mr. William T. Russell, Administrator Region I U.S. Nuclear Regulatory Commission l
631 Park Avenue Kireg of Prussia, PA 19406 Mr. Alexander W. Dromerick, Project Manager U.S. Nuclear Regulatory Commission Division of Reactor Projects I/II 7920 Norfolk Avenue, Phillips Bldg.
Bethesda, MD 20014 NRC Resident Inspector Oyster Creek Nuclear Generating Station 8709250460 870904 PDR ADOCK 05000219 0
PDR GPU Nuclear Corpormion o a suso. wary of the General Public Utikties Corporation g
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ATTACHMENT 1
V10I.ATIONA.
1 For components,10CFR50.55a(g)(4) requires that throughout the service life of the plant the if censee meet the requirements set forth in Section XI of the ASME Boiler and Pressure Vessel Code.
For Oyster Creek, the licensee uses the 1980 Edition of Section XI with 'Wiriter of _1981 Addenda.
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Subarticle IWA-4400, Pressure Test, under Article IWA-4000, Repair Procedure, in the above edition of the Section XI Code, requires that after repairs by welding on the pressure retaining boundary, a system hydrostatic test be performed.
(There are exceptions specified to this requirement but none that apply to this violation.)
Contrary to the above, as of May 21, 1987, weld RF-2-191X (the downstream weld of feedwater isolation valve V-2-11) was determined not to have been 1
hydrostatically tested following completion of. the weld. and required post maintenance testing and prior to plant operation.
RESPONSE TO VIOLATION A GPUN concurs with the violation as stated above.
A work package for major valve maintenance was released for production I
which included valve packing seal repairs for valve V-2-11.
Subsequent j
repairs to V-2-11 expanded the work scope to include cutting out the valve l
and later re-welding it back in the line.
The additional scope, because of the welding, required the performance of a hydrostatic test, and this j
requirement was identified.
However, the requirement to perform the hydrostatic pressure test was not incorporated as a specific post maintenance test.
Post Maintenance Test requirdiseMtTwere instead performed under a general work package developed to test many valves prior to plant startup.
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As required by ASME Code, an In-Service leak test was performed on the
.j packing. An additional ASME XI required pre-service examination due to the welding was identified, and the weld was examined utilizing ultrasonic 1
techniques.
No recordable flaws were noted.
However, a hydrostatic test at an elevated pressure was not performed at that time.
A system pressure test at 1.1 times normal operating pressure was subsequently performed on August 3,1987 to further demonstrate the acceptability of the weld.
Weld Package Information Requests (WPIR) are used to specify engineering requirements for plant welding activities, and are controlled under Welding Manual Procedure 6150-QAP-7220.01, " Control of Welding and Brazino".
This l
procedure will be revised to require that a copy of the completed WPIR be sent to the planner who initiated the request.
This will ensure that the planner is aware of any. testing requirements specified by Engineering and can include these requirements in the planning process in a timely manner.
A memo was issued on July 2,1987 to implement these changes immediately and the procedure revision will be issued by October 31, 1987.
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2 The corrective action stated above also addressed the communications concerns mentioned in the report.
This procedure change will assure'that test information/ requirements are transmitted to the WPIR originator, usually the job planner.
NRC Form NIS-2 was signed and submitted based on the initial operating pressure inspection performed on March 12, 1987. The need to submit a revised NIS-2 form addressing the post weld tests which have subsequently been performed is being evaluated.
This problem was an isolated case.
There were no other instances of similar work performed during the 11R refueling outage.
Therefore, this problem does not extend to other maintenance.
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Full compliance will be achieved with the issuance of the revised WPIR procedure, presently projected' for October 31, 1987.
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VIOLATION B Technical Specification Amendment;114 dated March 20, 1987 implemented requirements for the alternate shutdown monitoring instruments.
Technical Specification 3.12.I.1 of this Amendment requires that the alternate shutdown monitoring instruments listed in Table 3.12-6 be operable during reactor power operations and when reactor coolant temperature exceeds 212*F. Technical Specification 4.12.I.1 states "Each of the alternative' shutdown monitoring channels shall be demonstrated operable by performance of the channel check and channel calibration operations at the frequencies shown in Table 4.12-1."
Table 4.12-1 requires quarterly channel calibrations to be performed on reactor i
pressure and reactor water level -(fuel zone).
Contrary to the above, as of June 7,1987, while the reactor was operating at power and the reactor coolant temperature was above 212*F,
.j no channel calibration had been performed on reactor pressure and reactor 1
water level (fuel zone) since November 1986 when the instruments were i
placed in service nor were calibrations performed on or about March 20, j
1987 to demonstrate instrument operability prior to considering the j
l instrument operable in accordance with Amendment 114.
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RESPONSE TO VIOLATION B I
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I GPUN concurs with the violation as stated.
Oyster Creek procedure 664.3.006 for performance of the quarterly j
i calibration was prepared and subsequently executed on June 20, 1987.
l Additionally, procedurs 680.4.001 for performance of the required monthly channel checks was issued on August 7,1987.
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Additional emphasis will be placed on procedure revisions that will be required to comply with proposed technical specification amendments, as the technical specification change requests are submitted. Additionally, GPUN will routinely request an implementation period of 60 days prior to an amendment becoming effective to allow sufficient time for revised procedures to be issued.
I full compliance for the quarterly calibration was achieved on June 20, 1987 and for the monthly channel checks on August 7,1987.
Procedures for the calibrations required eaca refueling outage by l
Technical Specification Table 4.12-1 will be developed and issued prior to shutdown for the 12R refueling outage.
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VIOLATION C
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10 CFR 50.59, Changes, Tests, and Experiments, paragraph (b)(2) requires, l
"The licensee shall submit, as specified in 50.4, a report containing a j
brief description of any changes, tests, and experiments, including a summary of the safety evaluation of each.
The report must be submitted annually or at such shorter intervals as may be specified in the license,"
Contrary to the above, as of June 7,1987 the licensee had not submitted the annual reports required for the calender years 1985 and 1986. Also, i
the reports for the calender years 1983 and 1984 were submitted on March 1,1987 and March 30, 1987, respectively.
I RESPONSE TO VIOLATION C While requiring reports to be submitted " annually",10CFR50.59 does not assign specific submittal dates. Therefore, a timely submittal of a 10CFR50.59 report may be made any time during a given calendar year for I
modifications, tests, and experiments performed during the previous calendar year. Accordingly, GPU Nuclear responds to this violation as j
follows:
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GPUN agrees that the 10CFR50.59 reports for the calendar years 1983, 1984, and 1985 were not submitted in a timely manner.
The 1985 rrport was submitted on June 30, 1987.
2.
GPU Nuclear does not concur in this violation for the 1986 report.
The 198610CFR50.59 report will be submitted by October 31,1987, in compliance with NRC regulations.
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Full compliance was achieved with the submittal of the 1985 report.
In response to the NRC's concern that timely reporting should occur earlier in the calendar year, GPU Nuclear is scheduling the 1987 and all i
future 50.59 reports be submitted by the end of June of the subsequent
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year.
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