ML20247G561
| ML20247G561 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 05/14/1998 |
| From: | Roche M GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1940-98-20251, 50-219-97-11, NUDOCS 9805200282 | |
| Download: ML20247G561 (3) | |
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GPU Nuclear. Inc.
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U.S. Route #9 South NUCLEAR Post Office Box 388 l
Fork ad River, NJ 087310388 Tel M9714000 May 14, 1998 1940-98-20251 1
U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555
Dear Sir:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 IR 97-011 Reply to Notice of Violation In accordance with 10 CFR 2.201, the enclosed provides GPU Nuclear's response to the j
violation issued subsequent to the March 23,1998 predecisional enforcement conference.
If you have any questions, or require additional information, please contact Dennis Kelly of my staff at 609-971-4246.
Very tmly yours, I
b M
M j gp[
Michael B. Roche Vice President and Director
/
Oyster Creek MBR/DPK Attachment cc:
Administrator, Region I NRC Project Manager NRC Sr. Resident inspector e
9905200282 990514 PDR ADOCK 05000219 0
PM U
t ATTACHMENT 1 l
1 Violation 1 l
Title 10, Code of Federal Regulations, Part 50.59, " Changes, Tests, and Experiments,"
l (10 CFR 50.59), Section (a)(1) requires, in part, that licensees may make changes in the facility l
as described in the safety analysis report without prior NRC approval, unless the preposed change involves an unreviewed safety question. Section (b)(1) of 10 CFR 50.59 requires, in part, that licensee's records of changes in the facility must include a written safety evaluation which provides the bases for the determination that the change does not involve -an unreviewed safety question (USQ).
Contrary to the above, a written safety evaluation was not performed to provide the bases for the determination that a change in the facility as described in the safety analysis repon did not involve a USQ. Specifically, on January 15,1998, the licensee changed the primary containment configuration as described in the safety-analysis report, by using a freeze seal as the primary-4 containment boundary to replace a degraded containment spray heat exchanger relief valve, without performing an associated written safety evaluation. In addition, this change, that was made without prior NRC approval, resulted in a USQ due to the possibility of creating an accident or malfunction of a different type than any previously evaluated in the UFSAR.
This is a Severity Level IV violation (Supplement 1).
GPliN Response GPUN concurs with the violation as noted.
Reason for Violation Contrary to station procedure requirements, a safety determination was not completed as required prior to installation of the freeze seal. This failure was a human performance deficiency on the part of the planner in applying sufficient attention to detail and self-checking techniques.
In addition, thejob supervisor also failed to apply sufficient attention to detail and self-checking techniques.
Corrective Actions That Have Been Taken to Avoid Further Violations The two responsible individuals were subject to disciplinary action and the incident was reviewed with all Planners and Mechanical Maintenance Job Supervisors.
The incident was reviewed in all Maintenance shops to highlight the need to apply a sufficient level of detail to job order reviews and to fully comply with all job prerequisites, precautions and limitations.
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1940-98-20251 Page 2 In addition, the incident was reviewed with all Operations personnel to reinforce management's expectations concerning attention to detail and accuracy in log keeping.
Two actions were taken to addreas a wider audience. First, a Human Performance Eye Opener was issued summarizing the event and the human performance shortcomings. These informative documents are periodically issued for all site personnel to read.
Finally, a 10 CFR 50.59 Guio ace document was prepared for the safety review process that considered the activities of the past several years relative to the 10 CFR 50.59 process. This included Chairman Jackson's direction to the NRC Staff, NUREG 1606, potential rulemaking, industry guidance in NSAC-125 and NEl guidance in 96-07 " Guidelines for 10 CFR 50.59 Safety Evaluations". This Violation is specifically discussed in the Guidance and it was distributed to all safety evaluation preparers and reviewers.
l Corrective Actions That Will Be Taken to Prevent Recurrence i
A barrier analysis will be conducted to determine how this event occurred despite the barriers which should have prevented the occurrence. The outcome of the analysis will be used to revise the process as necessary.
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Date of Full Compliance Full compliance was achieved during the week of April 29,1998.
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