ML20235Q378
| ML20235Q378 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 02/09/1989 |
| From: | Fitzpatrick E GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8903020599 | |
| Download: ML20235Q378 (3) | |
Text
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- ==:;a88 GPU Nuclear Corporation Forked River, New Jersey 08731 o388 609 971-4000 Writers Direct Dial Number:
February 9,1989 US Nuclear Regulatory Commission Attention:
Document Control Desk Washington, DC 20555
Dear Sir:
Subject:
Dyster Creek Nuclear Generating Station Docket No. 50-219 IE Inspection 50-219/88-35 Response to Notice of Violation In accordance with 10 CFR 2.201, Enclosure A provides GPUN's response to the Notice of Violation contained in the subject Inspection Report.
GPUN concurs with the violation as stated.
We have included in our response information which we believe may liave warranted an exercise of discretion under 10 CFR Part 2, Appendix C.
This information was furnished generally to the inspectors at the exit and followed up with a telephone conversation and documentation.
If you have any questions regarding this response, please call Kathy Barnes, Oyster Creek Licensing at (609) 971-4390.
Very truly yours, E. E. Fit t
k Vice President and Director Oyster Creek EEF/KB/etar (0625A:23)
Enclosures cc: Mr. Alexander W. Dromerick, Project Manager U.S. Nuclear Regulatory Commission Division of Reactor Projects I/II Washington, DC 20555 NRC Resident Inspector Oyster Creek Nuclear Generating Station Forked River, NJ 08731 8903020599 s9020, F#5
$"DR ADOCK 0500o23g PDC GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation L_____-__--____--
1 NOTICE OF VIOLATION VIOLATION The Oyster Creek Technical Specification, Section 6.8.1 requires that written procedures be established and implemented to meet or exceed Regulatory Guide 1.33, Revision 2.
Regulatory Guide 1.33, Revision 2, Appendix A, paragraph 1.e. establishes administrative procedures for " procedure Review and Approval".
Licensee procedure, OCNG Station Procedure No.107, Revision 30, Paragraphs 3.5 and 5.3 states, "The Plant Review Group Chairman shall be responsible to assure that procedures are reviewed and approvM as required by this procedure..." and "0yster Creek station Procedures shall receive a review, l
comment, and approval cycle before distribution for use...".
Licensee procedure, GPU Nuclear Corporate Policy and Procedure Manual No.
l 1000-ADM-1218.01, Revision 2, Paragraph 4.6.7.2. states, "For signatures not i
appearing on the issued cover page...the approver's signature is required on i
the document.".
l Contrary to the above, on December 8,1988, the inspectors identified the i
following procedures that were issued without approval signatures.
1.
A100- ADM-3053.01, Revision 0, Calibration of Maintenance Test and Inspection Tools, Gauges and Instruments.
2.
A100-SMI-3225.02, Revision 0, CRD Differential Pressure Friction Test.
3.
A100-SMI-3422.01, Revision 0, Feedwater Regulating Valve Pneumatic Controllers Overhaul, Tests and Calibration.
l' GPUN RESPONSE GPUN concurs with the violation.
t GPUN concurs that the lack of an approval signature on the issued cover sheet l
of a procedure is a violation of GPUN's Corporate Procedure l
1000-ADM-1218.01.
However, in accordance with 10 CFR Part 2, Appendix C, an j
exercise of discretion may have been warranted based on the following summary i
of information that was provided to the inspectors.
j The discrepancy was self identified during a QA review of Maintenance, Construction and Facilities (MCF) activities in July 1988.
QA had identified i
a noncompliance in that the approval signature was replaced with "/s/" on tLe cover sheet of several MCF procedures that had been issued for use. Thi s l
noncompliance was documented in the field notes of the QA monitor and I
discussed with MCF, at which time the practice was iceased.
Subsequent to the exit meeting and the identification of this concern as a potential violation, QA performed a follow-up review and identified a total of 28 affected procedures. Although no additional procedures had been issued without the required signatures since MCF was made aware of the requirement, the 28 affecteo cover sheets had not been corrected. QA issued audit finding j
l S-0C-88-12 to MCF at this point to correct this discrepancy.
l l
L I
,~
The required approval signatures existed on file for all 28 affected procedures, however, they were replaced with "/s/" on the issued cover sheets.
During the development of MCF Maintenance procedures, the title block located on the header of the procedures was revised after these 28 procedures had been approved for issuance.
Since the title block had no effec t on the content of the procedure, the decision was made to transfer the signatures from the approved cover page to the revised one by using "/s/".
The noncompliance was administrative in nature with no safety significance since it involved the cover sheet signature, and actual approval signatures existed on file. At no time were unapproved procedures issued for use.
Corrective actions were taken in July and a review by QA determined that no procedures have been issued since then without the required approval signatures on the cover sheets. Twenty-six of the identified procedures have been reissued with the required approver's signature on each cover sheet.
Two remaining procedures, which were already being revised when the discrepancy was identified, will be issued upon approval with the required cover sheet signature.
Full compliance will be achieved on February 15, 1989.