ML20247E384
| ML20247E384 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 09/08/1989 |
| From: | Fitzpatrick E GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8909150272 | |
| Download: ML20247E384 (3) | |
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GPU Nuclear Corporation j
Nuclear e: en:r388 i
Forked River, New Jersey 08731-0388 609 971-4000 Writet's Direct Dial Number:
'l Septaber 8,1989 i
U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Dear Sir Subjects Oyster Creek Nuclear Generating Station Docket No. 50-219 Response to Notice of Violation Inspection Report 89-12 This letter is being written to respond to the Notice of Violation contained in Appendix A of Inspection Report 50-219/89-12. GPU Nuclear's response to this Notice of Violation, and the request for information contained in the cover letter of Inspection Report 89-12, are contained in Attachment I.
If you should need any further assistance, please contact Mr. John Rogers at (609) 971-4893.
Very truly yours,
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E.E. Fitzphtrick Vice President & Director Oyster Creek EEF/JR/je Attachment cc: Mr. William T. Russell, Administrator Region I g
fy U.S. Nuclear Regulatory Commission coa 475 Allendale Road y,
King of Prussia, PA 19406 ry n Mr. Alexander W. Dromerick
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U.S. Nuclear Regulatory Commission i
{40 Washington, DC 20555 OG NRC Resident Inspector j,'y Oyster Creek Nuclear Generating Station pD(
Gru a I I GPU Nuclear Corporation is a subsidiary oQhe General Public Utahties Corporation
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l Attachment I l
Violation:
10CFR50 Appendix B, Criterion 16 and CPU Nuclear Operational Quality Assurance Plan, Section B require, in part, that measures be established which ensure the conditions adverse to quality such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. The cause or significant conditions adverse to quality shall be determined and appropriate action taken to prevent recurrence.
Contrary to the above, established measures did not promptly identify and correct the following adverse conditions:
A.
Reactor coolant pressure boundary spring can hangers inadvertently left pinned for several weeks after the startup from 12R outcge. The cause of inadvertent pinning was not determined and appropriate action to prevent recurrence was not taken.
B.
Nonconservative reverse direction leak rate testing of four primary containment isolation valves (V-22-1, V-22-28, V-23-21, and V-28-47).
The cause of the nonconservative leak rate testing was not determined and appropriate action to prevent recurrence was not taken.
Reauest for Information:
In your response to the Notice of Violation, we request that you describe actions you are taking to increase the overall effectiveness of your corrective action programs.
Response
GPU Nuclear concurs in the violation. Each example cited above will first be addressed separately to identify requisite corrective actions.
Finally, a management overview to address increasing the effectiveness of the corrective action programs will be discussed.
Example As Immediate corrective action was taken to unpin the two identified hangers.
An engineering evaluation determined that the hangers were fully functional.
Both non-conformances were dicpositioned "use-as-is".
Additional hanger inspections were conducted, ana no other hangers were found pinned. A paperwork review of Outage 12R maintenance was conducted to ensure that work involving pinning had received proper close out.
No additional concerns were identified.
To ensure the effectiveness of the corrective actions taken, additional long term corrective actions were identified and implemented. The critique of this event was made required reading for appropriate maintenance personnel. A Technical Functions task request was issued to incorporate lessons learned from Outage 12R and this event into appropriate procedures. Procedure A000-WMS-1221.08 "MCF Job Order" was revised to establish requirements relating to Job Order execution and revision.
Clarification of " pen and ink" and "non-substantive" changes to procedures were also included.
Full compliance was achieved with the completion of the hanger inspections and paperwork review specified above.
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The original concern with-wrong direction testing addressed 13 valves. The l
following immediate corrective actions were taken:
1.
Written justification of testing practices were provided where possible.
2.
_ Procedure changes were generated to eliminate reverse direction testing where possible.
This eliminated nine of.the 13 original valves. For the remaining four valves:
3.
Justification of valve operability was provided through an engineering evaluation.
4.
A Deviation Report was issued to escalate the level of management attention.
To ensure the effectiveness of the corrective action program, long term corrective actions were initiated to identify replacement valves which can be conservatively tested in the reverse direction. Additionally, these replacement valves will be purchased and installed where justification for reverse direction testing could not be provided.
Full compliance was achieved with the completion of the immediate corrective actions on June 8, 1989. Requisite modifications will be implemented as plant conditions permit, and will be completed prior to restart from refueling outage 13R.
'Manacement Overview on Corrective Actions Procrams Prior to the identification of this violation, GPU Nuclear had embarked on a series of efforts specifically designed to strengthen corrective action programs. These efforts were accelerated and reinforced by this violation. A complete rewrite of Corporate Procedure 1000-ADM-7330.01 " Management of Potential Safety Concerns" was initiated and approved in the second quarter of 1989. Additionally, Oyster Creek site procedure 104, " Control of Non Conformances and corrective Action" was revised, including a complete restructuring of Form 104-1 " Deviation Report".
Specific references to Corporate Procedures 1000-ADM-7215.02 "GPUN Quality Deficiency Report" snd lOOO-ADM-1201.01 " Incident critigpe Procedure" were included. Required documentation for closecut of a Deviation Report was strengthened, especially in those events where the incident is concluded to be not reportable under 10CFR50.73.
Finally, a task group was established to review and recommend changes to site procedure 108 " Equipment Control".
Specifically, they were tasked with ensuring that the administration of temporary variations from existing plant configurations is adequate and thorough. The specified revision was issued on July 16, 1989.
This level of effort and scope of response were designed to significantly decrease the probability of a similar corrective action inadequacy. The strengthening of individual site programs when coupled with corporate involvement should result in an overall improvement in corrective action response.
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