ML20237C205

Responds to NRC Re Violations Noted in Insp Rept 50-219/87-28.Corrective Actions:Procedure Revised & Computer Program Implemented to Track Discrepancy Repts & Flag Untimely Responses

ML20237C205
Person / Time
Site:	Oyster Creek
Issue date:	12/10/1987
From:	Heward R GENERAL PUBLIC UTILITIES CORP.
To:	Johnston W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8712210132
Download: ML20237C205 (3)

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GPU Nelear Corporation arsippany, New Je sey 07054 201-316-7000 December 10, 1987 TELEX 136-482 Writer's Direct Dial Number:

William V. Johnston, Acting Director Division of-Reactor Safety U.S. Nuclear Regulatory Commission 631 Park Avenue

'rsing of Prussia, PA 19406

Subject:

Oyster Creek Nuclear Generating Station Docket No. 50-219 Inspection Report NO. 60-219/87-28 Response to Notice of Violation The attachment to this letter provides GPU Nuclear's response to the Notice of Violation in Appendix A to your letter dated November 10, 1987.

If further information is required, please contact Mr. Michael Heller, OC i

Licensing Engineer at (609)971-4680.

Very truly yours, R. W. Heward, Jr.

Vice President & Director i

Maintenance, Construction &

l Facilities RWH:MH:dmd (0268A) l Att achment cc: Mr. William T. Russell, Administrator Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King 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 I Oyster Creek Nuclear Generating Station 8712210132 871210 gDR ADOCK 05000219 '

DCD GPU Nuclear Corporation is a subsidiary of General Public Utihties Corporation g (

ATTACHMENT I Violation:

As a result of the inspection conducted on September 28-October 2, 1987, and in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C), the following violation was identified:

10 CFR 50 Appendix B, Criterion XII states: " Measures shall be established to assure that ... measuring and testing devices ... are controlled, calibrated, and adjusted at specified periods ....d The licensee has committed to ANSI N18.7-1976, paragraph 5.2.16, that requires that "When calibration, testing, or other measuring devices are found out of calibration, an evaluation shall be made and documented concerning the validity of previous tests and the acceptability of devices previcusly tested from the time of the previous calibration."

OCNGS Procedure 112, Attachment 6, " Controlled Test Equipment Discrepancy Investigation Card", requires users of the discrepant test equipment to review the usage history and report the results of their evaluation.

Contrary to the above, as of October 2,1987, the validity of previous calibration tests of installed plant equipment and the acceptability of that equipment were not being evaluated in that for Controlled Test >

Equipment Discrepancy Investigation Cards issued between May 8,1986 and April 12, 1987 for out of calibration test equipment, 18 instances were identified in which neither the validity nor the acceptability of calibration tests performed by that test equipment were being evaluated.

This is a severity level V violation (Supplement I).

GPUN Response:

GPUN concurs with the violation after clarification that the 18 identified discrepancy evaluations were being processed, although not in a timely manner. GPUN had previously identified problems with discrepancy report format, adequacy of corrective action documentation, and timeliness of response. The following corrective actions have been completed:

(1) Evaluations of the 18 identified Maintenance and Test Equipment '

(M&TE) discrepancies have been completed and documented. The evaluations included a thorough review of prior usage of the M&TE and comparison of the out-of-tolerance condition with the accuracy required for previous inspections performed with the M&TE. All previous inspections were determined to be valid. No re-work or additional testing has been required in any case.

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(2) The administrative procedure controlling this activity has been revised to require increased management oversight, more complete documentation of corrective action, and a more thorough review of the corrective action process.

(3) Additionally, a computer program has been implemented to track discrepancy reports and " flag" untimely responses.

Full compliance was achieved with the completion of items 1 and 2 above on October 28, 1987.

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