ML20237C562
| ML20237C562 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 08/14/1998 |
| From: | Roche M GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1940-98-20458, 50-219-98-03, 50-219-98-3, NUDOCS 9808210273 | |
| Download: ML20237C562 (7) | |
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GPU Nuclear, Inc..
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U.S. Route #9 Soutti NUCLEAR Post Office Box 388 Forksd her, NJ 08731-0388 Tel 609-971-4000 August 14, 1998 1940-98-20458 l
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U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 j
Dear Sir:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 IR 98-003: Reply to Notice of Violations r
In accordance with 10CFR 2.201, the enclosed provides GPU Nuclear's response to the violations identified in the subject inspection report.
I If you should have any questions, or require further information, please contact Brenda DeMerchant, Oyster Creek Regulatory Affairs Engineer, at 609-971-4642.
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Very truly yours,
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I Michael B. Ro e k Vice President and Director Oyster Creek i
MBR/BDE/gl Attachment i
cc:
. Administrator, Region I NRC Project Manager
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NRC Sr. Resident Inspector l
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9808210273 980814 PDR ADOCK 05000219 l
G PDR I
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3 Attachment I
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Violation 1 l
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The Code 'of Federal Regulations,10 CFR, Part 50, Appendix B, Criterion XV (Nonconforming
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l Materials, Parts, or Components) requires that measures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent
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use or installation. These measures shall include, as appropriate, procedures for identification, l
documentation, segregation, disposition, and notification to affected organizations, i-Nonconforming items, shall be reviewed and accepted, rejected, repaired or reworked in accordance with documented procedures.
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Oyster Creek Nuclear Generating Station (OCNGS) procedure 125.2.10, Receipt Deficiency -
Reports, revision 2, requires, in part, the action party for a deficiency to provide a proposed I
disposition to resolve the deficiency (Use-As-Is, Repair, Rework, Scrap, Other), and the Configuration Maintenance Manager to evaluate the proposed disposition and either concur or l.
provide the required disposition.
Contrary to the above, on or about June 9,1998, the licensee failed to review and disposition a nonconforming emergency diesel generator starter motor in accordance with OCNGS procedure 125.2.10.
This is a Severity Level IV violation (Supplement I).
Response
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GPU Nuclear concurs with the violation as written.
Reason for Violation Due to the fact that the plant was in a Technical Specification Limiting Condition for Operations, the job supervisor was focused on replacing the Number 1 Emergency Diesel Generator (EDG) starter motor with an in kind replacement th' s overlooking the administrative requirement to u
disposition the deficiency of the nonconforming starter motor per Procedure 125.2.10.
During pre-service testing the starter motor faile'd to respond as required and the supervisor was informed of the problem. During the supervisor's investigation he realized that ajumper was
~ installed that set up the starter motor for single operation rather than two starters in series as required for Oyster Creek's diesels. Based on his knowledge and experience, the job supervisor l
directed that the replacement starter be configured to match the installed starters and that the starter be fully tested in accordance with approved procedures. The starter tested satisfactorily and was installed in the Number 1 EDG. Post maintenance testing was performed satisfactorily i
and the EDG was returned to operation.
The fact that Procedure 125.2.10 was not followed was identified during the cognizant engineer's post maintenance review.
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Attachment I 1940-98-20458 Page 2 of 6
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Corrective Steos Taken and Results Achieved Corrective Action Program (CAP) reports were generated to investigate the failure to document the deficient condition and to determine if a 10 CFR 21 report should be made. Also, a Receipt Deficiency Report (RDR) was written to capture action taken to configure the starter motor.
This RDR was dispositioned to use the starter motor as configured with thejumper removed.
Corrective Steos Taken to Avoid Further Violations An additional CAP was generated to document the failure to administratively control the configuration change to the starter motor.
As per 10CFR, Part 50, Appendix B, Criterion XV, measures are in effect under OCNGS procedure 125.2.10 to manage configuration control preventing inadvertent use or installation of material. This event occurred due solely to an inappropriatejudgement by the supervisor. The supervisor has discussed configuration control with the Electrical Superintendent and the Configuration Control Manager. This event has also been discussed in the electrical shop meetings.
A review of the need to submit a 10 CFR 21 report in accordance with GPUN procedure 1000-l ADM-1290.01 is ongoing.
Date When Full Comoliance was Achieved Full compliance was met when the Receipt Deficiency Report (RDR) was dispositioned as stated above.
Violation 2 License Condition 2.C.3, Fire Protection. of Facility Operating License DPR-16, for the OCNGS, states, in part, "GPU Nuclear Corporation shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the Updated Final Safety Analysis Report for the facility and as approved in the Safety Evaluation Report dated March 3,1978, and i
supplements thereto..."
l Section 9.5.1, Fire Protection Systems. of the Updated Final Safety Analysis Report, states that i
OCNGS procedure 101.2, Fire Protection Program, is considered included in the Fire Protection Program.
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- Attachment I 1940-98-20458 Page 3 of 6 Contrary to the above, GPU Nuclear Corporation did not implement and maintain in effect all provisions of the approved Fire Protection Program as indicated by the following examples:
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OCNGS procedure 101.2, Fire Protection Program, directs that fire watches be established in accordance with OCNGS procedure 120.2, Fire Watch Instructions.
Section 4.2.2, OCNGS procedure 120.2, Fire Watch Instructions, Subsection 4.2.2.1.3 l
requires that a fire watch turnover shall include a review of the Fire Watch Assignment Forms.
On May 18,1998, the fire watch turnover failed to include a review of the Fire Watch Assignment Forms.
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Section 4.4, OCNGS procedure 101.2, Fire Protection Program, states, in part, that fire watches shall provide required notification and possible extinguishment of a fire when a fire protection system is impaired or inoperable.
On August 1,1997, no fire watch was assigned to provide notification and possible I
extinguishment of a fire in the exciter when the turbine generator exciter high pressure CO system was inoperable.
2 This is a Severity Level IV violation (Supplement I).
Resnonse to Examnie " A" I
GPUN concurs with the violation and offers the following additional information:
Reason for Violation Due to their familiarity with the existing impairments, the firewatch personnel used the Fire Watch i
Inspection Log which provides a listing ofimpairments rather than the individual Fire Watch Assignment Forms as described in the procedure. Even though the individual forms were not reviewed, the firewatch was knowledgeable of the impairments and performed an appropriate j
tour.
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Corrective Steps Taken and Results Achieved Management's expectations were reviewed with all firewatch personnel regarding their roles and responsibilities. In addition, a review of proper turnover techniques including usage of the l
Inspection Log and the Assignment forms, and the purpose for both of these documents was held sh all firewatch personnel.
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Attachment I 1940-98-20458 Page 4 of 6
- Corrective Stens Taken to Avoid Further Violations The Fire Protection Coordinator has distributed these violations and the associated NRC Inspection Report to the fire watch personnel and operations supervisors in order to heighten their
. awareness and sensitivity to these issues.
The Fire Protection Coordinator has reinforced management's expectations and standards regarding procedure compliance and proper turnover techniques with all fire watch personnel.
The Fire Protection Coordinator will review and revise (as appropriate) the Fire Watch Instructions regarding the turnover process to enhance and simplify our existaig process. The appropriate revisions will be completed by November 1,1998.
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Date When Full Comoliance Was Achieved
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- Full compliance was achieved on August 7,1998 with issuance of a memorandum reinforcing
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- management's expectations and standards regarding proper turnover techniques.
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Resnonse to Example "B" l
1 GPUN concurs with the violation as written.
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-- Reason For Violation
. When the turbine generator exciter high pressure CO2 system was removed from service to support routine maintenance activities, a fire watch was not assigned because of a procedural deficiency. The turbine generator exciter high pressure CO2 system is not contained in the Oyster Creek Fire Protection Program Technical Requirements (Attachment 101.2-3). This attachment provides fire watch requirements for inoperable fire detection equipment, suppression systems and
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associated instrumentation in safety related areas and zones. Since the exciter is not a safety j
related or safe shatdown required component, no specific compensatory measures are contained within Attachment 101.2-3. As such, a firewatch was not assigned when this system was removed from service contrary to the requirements of the plant's Fire Protection Program.
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Attachment I 1940-98-20458 Page 5 of 6 Corrective Steos That Have Been Taken And The Results Achieved.
Procedural changes have been implemented to define and clarify the compensatory measures for balance of plant systems and components within the Oyster Creek protected area. Revision 28 f
was issued to Procedure 101.2, effective June 15,1998, which provides clarification and additional directions.
j Corrective Steps That Will Be Taken To Avoid Further Violations i
Following the exciter fire, the following additional precautions were instituted to preclude l
recurrence:
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Revised the PM task for exciter maintenance to add a precaution for portable fire e
extinguishers to be staged prior to removing the system from service and for personnel exiting the area to ensure the doors to the area are closed.
1 Instructed Operations to minimize the time period that the CO Suppression System was 2
out of service.
Established a requirement to assign an hourly firewatch whenever the exciter suppression system is out of service for longer than eight hours.
l Date When Full Compliance was Achieved Full compliance with the requirement to appropriately identify and assign firewatches for non-safety related/ safe shutdown areas was achieved on June 15,1998 when the revised procedure i
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l Violation 3 License Condition 2.C.3, Fire Protection. of Facility Operating License DPR-16, for the OCNGS, states, in part, " GPU Nuclear, Inc. shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the Updated Final Safety Analysis Repon for the facility and as approved in the Safety Evaluation Report dated March 3,1978, and supplements thereto.. "
Section 3.2.4, Communications Eauipment. of Supplement No. 3 to the Safety Evaluation Report dated March 3,1978, requires the licensee to install fixed repeaters to assure that adequate l
communications capability would be available for fire fighting and safe shutdown activities.
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Attachment I
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1940-98-20458 Page 6 of 6 Contrary to the above, on or before August 1,1997, communications that were required for fire fighting and safe shutdown activities were inadequate. Specifically, the licensee failed to adequately maintain and test the installed radio repeater backup battery power supply.
This is a Severity Level IV violation (Supplement I).
Response
GPUN concurs with the violation as written.
Reason for Violation I
i The violation occurred due to inadequate preventive maintenance. The preventive maintenance f
on the radio communication system did not adequately maintain and test the installed radio repeater backup battery power supply.
Corrective Steps That Have Been Taken and The Results Achieved 1
The radio communication repeater's backup batteries were replaced on November 24,1997. The repeater was then tested on battery power only to verify proper operation. Radio repeaters are working normally with backup battery power on a float charge.
Corrective Stcos That Will Be Taken to Avoid Further Violations A preventive maintenance task was written to replace repeater batteries every four years. In addition, a preventive maintenance task was developed to perform a yearly float voltage check on the repeater backup battery power supply. All preventive maintenance tasks have been written end scheduled.
Date When Full Comoliance Was Achieved Full compliance for the repeater backup battery power supply was achieved on November 24, 1997, when the batteries were replaced and tested.
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