ML20235H856
| ML20235H856 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 02/14/1989 |
| From: | Phyllis Clark GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8902240076 | |
| Download: ML20235H856 (7) | |
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GPU Nuclear Corporation A
lggy One Upper Pond Road awMu Parsippany, New Jersey 07054 201-316-7000 TELEX 136-482 Writer's Direct Dial Number:
February 14, 1989 i
Director Office of Enforcement U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 i
Dear Sir:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 License No. DPR-16 Reply to a Notice of Violation The enclosure to this letter provides GPU Nuclear Corporation's (GPUN) reply to the Notice of Violation forwarded to GPUN by letter dated January 18, 1989 from the Regional Administrator, Region I, U.S. NRC. The reply is in accordance with 10 CFR 2.201 and the Notice of Violation.
The Notice of Violation concerns the violation of a technical specification safety limit and preceding events which resulted in violating the safety limit at Oyster Creek. Activities which caused a leak at the reactor building closed cooling water system isolation valve were improperly controlled. Had they been adequately coordinated, the leak could have been prevented and the circumstances which resulted in the safety limit violation could have been averted.
The safety limit violation, the improper control of valve maintenance activities and the destruction of a sequence of alarms tape relating to the safety limit violation by an on-shift control room operator have been of great concern to us. GPUN undertook prompt and comprehensive investigatory and corrective actions in response to these concerns and has completed those actions with one exception as noted in the enclosure.
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GPU Nuclear Corporation is a subsidiary of General Public Utilities Corporation l
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,.The events which form the basis for the Notice of Viciation and proposed Civil Penalty did occur.
In view of this and other factors the NRC has considered in proposing the Civil Penalty, we enclose a check in the amount of fifty thou. sand dollars ($50,000) for payment of the Civil Penalty.
Very truly yours, P. R. Clark President Sworn to and subscribed before me this
/Y day of /G b r o,--
1989.
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La vw Notary public / /
~PRC:crb NANCY HOFFMAN Enclosure NOTARY PUBUC OF NEW ERS$Y My Commission Expires 9. 7 7 / 7 I cc: Regional Administrator Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Resident Inspector Oyster Creek Nuclear Generating Station Mr. Alex D'romerick U.S. Nuclear' Regulatory Commission Mail Station P1-137 Washington, DC 20555 l
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ENCLOSURE REPLY TO NOTICE OF VIOLATION GPU NUCLEAR CORPORATION DOCKET NO. 50-219 OYSTER CREEK NUCLEAR GENERATING STATION LICENSE NO. DPR-16 As a result of events which occurred at Oyster Creek on September 11, 1987, a technical. specification safety limit was violated. The NRC identified specific violations of NRC requirements which were set forth in a Notice dated January 18, 1989. The violations and GPU Nuclear Corporation's (GPUN) reply, pursuant to 10 CFR 2.201 and the Notice, are as follows:
Violation A Technical Specification 2.1.E, Safety Limits, requires that, during all modes of operation, except when the reactor head is off and the reactor is flooded to a level above the main steam nozzles, the suction valves and associated discharge valves in at least two of the five recirculation loops shall be in the full open position.
Contrary to the above, between approximately 2:17 a.m. and 2:19 a.m. on September 11, 1987, while the plant was in the shutdown condition with reactor water level at normal and the reactor vessel head on, less than two of the five recirculation loop discharge valves were in a full open position.
GPUN Reply to Violation A Admission or Denial of the Alleged Violation GPUN admits that the technical specification safety limit violation occurred, as stated.
Reasons for the Violation The cause of the safety limit violation is attributed to personnel error by a control room reactor operator. The root and contributory causes of the l
personnel error are detailed in GPUN letter (PNS-87-0105) dated October 14, 1987 as corrected and resubmitted by GPUN letter dated December 1, 1987.
Corrective Steps Taken and Results Achieved Corrective actions included re-emphasizing to the operators the importance of adherence to approved procedures, revisions to several procedures related to operation of the recirculation system, and additional operator training which also addresses recirculation pump operation during off-normal conditions, including " hands-on" training at the Basic Principles and Full Scope Simulators. GPUN letters dated September 20, 1987 and October 14, 1987 (PNS-87-0105) as corrected and resubmitted by letter dated December 1,1987 further describe the corrective measures taken to avoid a recurrence of this violation.
GPUN believes that these measures have been effective in improving operator understanding and awareness of proper recirculation system operation during both normal and off-normal conditions. 8095f
Date When Full Compliance Will Be Achieved NRC Inspection Report No. 50-219/87-34 documented the inspection of corrective actions implemented prior to plant restart following the safety limit violation. These, and other corrective actions which were implemented subsequent to plant restart, are complete.
Full compliance has been achieved.
In addition to the corrective measures taken to ensure compliance with NRC j
requirements, GPUN has evaluated the technical specifications associated with recirculation loop operation.
A license amendment application was submitted on March 31, 1988, which proposes changes to requirements for recirculation loop operation which are appropriate for different plant conditions, reflect the results of our analyses and we believe are consistent with the definitions of safety limit and limiting conditions for operation in 10 CFR 50.36.
Violation B Technical Specification 6.8.1 requires that written procedures shall be established, implemented and maintained.
1.
Station Procedure 107, Procedure Control, Revision 32, Step 5.3.5.1, requires that no prerequisites, precautions, or acceptance criteria can be changed in a procedure without the approval of either the Plant Operations Director, Manager Plant Operations, Operations Control Manager, Manager Plant Material, Plant Engineering Director, Director / Deputy Manager Radiological Controls (Rad Con requirements only), PRG Chairman or Vice Chairman, or Director / Deputy Director.
Contrary to the above, shortly after 2:00 a.m. on September 11, 1987, while maintenance was being performed on a Reactor Building Closed Cooling Water (RBCCW) System isolation valve (No. V-5-167), using Station Procedure 700.1.030, an attempt was made to repack the valve while on its backseat, rather than isolated and vented as required by the procedure prerequisites, representing a change in Station Procedure 700.1.030 without obtaining the approval of any of the designated management individuals set forth in Station Procedure 107.
2.
Station Procedure A100-SMM-3917.06, manually Backseating Station Valves, Revision 0, in part, specifies the instructions for manually backseating station valves with Limitorque operators, and states that if the valve is unable to be backseated manually due to location, radiation levels, etc., the valve may be electrically backseated in accordance with j
Procedure 700.2.012 with engineering approval.
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Station Procedure 700.2.012, Electrically Backseated Station Valves, l
Revision 3, Prerequisite 3.4, requires, in part, that the Group Shift l
Supervisor sign the data sheet indicating that permission has been granted to perform this backseating operation.
Further, Precaution and Limitation 4.1, states, in part, that only valves listed in Attachment I of Station Procedure 700.2.012 may be backseated utilizing this procedure, and if another valve requires backseating, Plant Engineering approval is required with regard to applicability of the valve to this l
procedure.
Contrary to the above, during the 8:00 a.m. to 4:00 p.m. shift on September 10, 1987, Valve No. V-5-167, which was not a valve listed in Attachment I of Procedure 700.2.012, was electrically backseated without permission beint, obtained from Plant Engineering and without the Group Shift Supervisor signing a data sheet granting permission to electrically backseat the valve.
3.
Station Procedure 108, Equipment Control, Revision 38, Step 5.1.9, I
I specifies, in part, that if equipment or piping is to be opened, valves and switches shall be aligned and tagged so as to insure that the work does not present a hazard to personnel or equipment from pressure, vacuum, fluids, gases, or radioactive contamination.
Further, Step 5.1.15 requires in part, that if a tag is placed on a component's power supply, a tag shall also be placed on each remote control. A tag need not necessarily be placed on the component's manual operator if the manual operator or its associated components are not part of the safety boundary.
Contrary to the above, although the manual operator for RBCCW Isolation valve No. V-5-167 was repacked on September 11, 1987, and operation of this valve affects the safety boundary, the valve was not tagged, as
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required.
GPUN Reply to Violation B Admission or Denial of the Alleged Violation GPUN admits that the procedure non-compliances cited above occurred. These procedure non-compliances occurred during a maintenance activity which involved repacking the stem of an isolation valve in the Reactor Building Closed Cooling Water System. A leak resulted while packing was being removed from the valve stem because the valve was improperly backseated. During actions taken in response to the leak, a technical specification safety limit was violated as described in Violation A.
A detailed discussion of the maintenance activity including description of circumstances, cause evaluation and proposed corrective actions was provided to the NRC by GPUN letter dated September 22, 1987, " Spill of Reactor Building Closed Cooling Water during Maintenance".
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i Reasons for the Violation l
The primary reason for this violation is personnel error. Procedure compliance is a GPUN policy.
In addition, when procedures inadequately address the performance of a specific evolution as planned, a procedure change is in order. The personnel involved should have initiated appropriate temporary changes, where needed.
Other factors were noted to have contributed to the procedure non-compliances, as follows:
Station administrative procedures were not clear in assigning responsibilities for operations and maintenance personnel.
Communication was noted to be weak during shift or personnel turnovers.
The planning and implementation of this valve maintenance was performed over a period of several 8-hour shifts.
The completeness of the training on valve motor operators may also have been a factor in this event.
Corrective Steps Taken and Results Achieved Following the maintenance evolution., which was performed while the plant was shutdown, GPUN critiqued the event.
As a result, corrective actions were identified and implemented as described in our September 22, 1987 letter. The corrective actions were as follows:
"The following corrective actions will be taken prior to restart:
1.
procedures for the operations / maintenance interface will be revised to more clearly assign responsibilities. Operators and maintenance personnel will have these responsibilities emphasized to them as part of a training session.
2.
Operations and maintenance management will stress the importance of procedural compliance to their personnel. Training will be provided on switching and tagging requirements and approved valve backseating techniques to appropriate personnel. Additionally, maintenance management will issue a policy providing guidance to maintenance supervisors on proper job turnovers during shift changes.
3.
Detailed information relating to control logic of the valve motor operator and a copy of the critique of this event will be placed in the required reading programs for appropriate personnel.
The following corrective actions will be completed prior to December 31, 1987:
1.
Specific procedures relating to backseating and unbackseating of valves will be combined into a single procedure under the control of the Operations department. The maintenance procedure which was applicable to repacking the valve during this event, will be revised to identify prerequisites, precautions, and limitations which will allow safely repacking this valve on its backseat. 8095f
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Maintenance department will issue a procedure tc formalize its policy on proper job turnover during maintenance.
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Formal training will.be provided to appropriate personnel on specific details 'of valve motor operator control logic.
4.
A Management Oversight and Risk Tree (MORT) analysis will be performed on this event to ensure that no additional attributing causes were omitted."
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GpVN believes that the above measures improve the control of work and provide additional assurance in avoiding further. violations.
Date When Full Compliance Will 'Be Achieved L
The identified corrective actions have been completed, with the exception of item 2.
A procedure formalizing maintenance department policy. on proper job turnover ~during maintenance activities was developed and a'pproved in December 1987 but was not administrative 1y invoked. The guidance therein will be distributed in Oyster Creek Maintenance Procedure A100-ADM-7150.01 effective March 15, 1989. As previously noted, a policy on job turnover was issued via memorandum on September 28, 1987.
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