ML20248E208

Responds to Violations Noted in Insp Rept 50-219/98-80. Corrective Actions:High Drywell Pressure Daily Checks Were Satisfactorily Completed After NSSS Leak Test Was Placed Into Effect Prior to Startup from 16R Outage

ML20248E208
Person / Time
Site:	Oyster Creek
Issue date:	05/22/1998
From:	Roche M GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
1940-98-20273, 50-219-98-80, NUDOCS 9806030226
Download: ML20248E208 (8)

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l GPU Nuclear,Inc.

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( U.S. Route #9 South orked R ve NJ 08731-0388 Tel 609-971-4000 May 22, 1998 1940-98-20273

' U. S. Nuclear Regulatory Commission

. Attention: Document ControlDesk Washington,DC 20555

Subject:

Oyster Creek Nuclear Generating Station Docket No. 50-219 IR 98-080: Reply to Notice of Violations In accordance with 10CFR 2.201, the enclosed provides GPU Nuclear's response to the violations identified in the subject inspection report.

If you rhould have any questions, or require further information, please contact Brenda DeMerchant, Oyster Creek Regulatory Afhirs Engineer, at 609-971-4642.

Very truly yours,

) biYu Michael B. Roche Vice President and Director Oyster Creek MBR/BDE/gl Attachment cc: Administrator, Region I NRC Project Manager NRC Sr. Resident Inspector i

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Attachment 1

. Response to Notices of Violation l

Violation A A. Technical Specification (TS) 3.4.B.1 requires that: "Five electromatic relief valves of the automatic depressurization system shall be operable when the reactor water temperature is greater than 212 degrees F and pressurized above 110 psig, except as specified in 3.4.B.2.

The automatic pressure relief function of these valves (but not the automatic depressurization function) may be inoperable or bypassed during reactor vessel p'ressure testing consistent with T.S.1.39 and 3.3.A.(I)." TS Table 3.1.1, Item G.1 requires High Drywell pressure instrumentation to be operable to support ADS operability. TS 4.1.1, Item 9 requires the High Drywell pressure instruments to be channel checked once per day.

Contrary to the above, on October 6,1996, when the automatic depressurization function was required during the Reactor Vessel Pressure Test, GPUN failed to perform the required High Drywell Pressure Channel Check in accordance with T.S. 4.1.1. Item 9, and therefore, failed to ensure Automatic Depressurization System (ADS) operability as required by TS 3.4.B.I.

This is a Severity Level IV violation (Supplement I).

Response

GPU Nuclear concurs with the violation as stated. This event is described in detail in LER 98-003, dated March 31,1998.

Reason for Violation:

The violation occurred because the procedure which controls the Nuclear Steam Supply System (NSSS) Leak Test does not contain a step requiring performance of drywell pressure instrument checks. This oversight was due to the drywell being opened to atmospheric pressure throughout the NSSS Leak Test. All other requirements for ADS operability were completed.

Corrective Steos That Have Been Taken and the Results Achieved:

The high drywell pressure daily checks were satisfactorily completed shortly after the NSSS Leak Test when primary containment was placed into effect prior to startup from the 16R outage.

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Corrective Stens That Will Be Taken to Avoid Further Violations:

The procedure that controls the NSSS Led Test will be revised to ensure the required surveillance testing with regard to ADS is completed. This procedure will be revised by August 31,1998. In addition, operator training will be provided on this event.

Date of Full Comoliance:

Full compliance was achieved when the high drywell pressure daily checks were satisfactorily completed shortly after the NSSS Leak Test when primary containment was placed into effect prior to startup from the 16R outage.

Violation B (1) 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires in part that: " Activities affecting ouality shall be prescribed by documented instructions, procedures or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."

Contrary to the above, GPUN personnel failed to follow established procedures for calculations and safety evaluations involving safety related activities in the following two instances:

In early 1996, calculations to support the seismic adequacy of safety-related equipment (to address issues of NRC Generic Letter 87-02, Revision 1) were not verified as required by Procedure EP-06, Revision 3.03.

I Resnonse:

GPU Nuclear concurs with the violation as stated.

Reason for Violation:

The calculation to resolve the outlier for the anchorage of the containment spray heat exchangers identified during the walkdowns performed in response to GL 87-02 was not design verified as required by Procedure EP-006. However, the SQUG summary report prepared in response to the generic letter stated that the outlier for the containment spray heat exchangers had been resolved. The reason for the violation is that engineering personnel did not place appropriate priority on the completion of the design verification j process. Since a caleclation had been prepared and since the calculation demonstrated )

that the anchorage for the heat exchanger was adequate, priority was placed on modifications of comp 3nents required to resolve other outliers identified in the SQUG summary report.

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In addition, a number of administrative and technical issues delayed completion of the

. . design _ verification. On February 2,1998, a new analysis of the heat exchanger anchorage was begun. The design verification for the revised calculation is expected to be complete by June 30,1998. The calculation continues to show that the anchorage for the heat exchangers is adequate.

Corrective Steps That Have Tp Taken and Results Achieved:

Subsequent to the identification of the violation, GPU Nuclear determined that additional calculations for items reported in the SQUG summary report as " . resolved by subsequent analysis" had not been design verified. Based on these discrepancies, GPU Nuclear has taken and is planning a number of steps to avoid further violations.

, The calculation for the anchorage of the containment spray heat exchangers is underway I

and the design verification is expected to be complete by the end of June,1998. The schedule for completion of the other SQUG calculations is contained in the revised SQUG summary report previously submitted to the NRC.

In addition, GPU Nuclear is revising Procedure 1000-ADM-1216.03, " Regulatory Correspondence Control," to clarify GPU Nuclear's policy regarding when design verifications are required and when they must be completed. Documents that support statements / conclusions in submittals to the NRC are to be completed in accordance with GPU Nuclear procedures. This includes the requirement that a design verification be completed for all calculations within the scope of the GPU Nuclear Operational Quality Assurance Plan. The revision of this procedure is expected to be effective by the end of June,1998. In addition, GPU Nuclear recently revised the corporate calculation procedure (EP-006), to clearly state that any required design verifications must be complete prior to release of any calculations. While the revision to EP-006 was not performed in response to the NOV, it does clarify the GPU Nuclear policy with regard to the necessity of completing the required design verifications.

I Corrective Stens That Will Be Taken to Avoid Further Violations:

1 Training has been scheduled during the month of June,1998, for all Engineering Support Personnel. This training will emphasize the importance of and the requirement to complete design verifications as required by GPU Nuclear policy and procedures. In addition, GPU Nuclear is presently reviewing other calculations to determine if similar discrepancies exist.

Date when Full Comoliance Will Be Achieved:

- Upon completion of the calculation and design verification to resolve the outliner for the anchorage of the containment spray heat exchangers, full compliance will be achieved.

This is currently scheduled for the end of June,1998.

Violation B (2) 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires in part that: " Activities affecting quality shall be prescribed by documented instructions, procedures or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."

Contrary to the above, GPUN personnel failed to follow established procedures for calculations and safety evaluations involving safety related activities in the following two instances:

l On February 26,1998, there were numerous examples of non-compliance with Procedure EP-016, Nuclear Safety / Environmental Determination and Evaluation, which required a  !

printed name and signature for engineer / originator, section n anager or project manager (for AEs), responsible technical reviewer, independent safety reviewer, and other reviews as applicable.

This is a Severity Level IV Violation (Supplement I).

GPUN Response:

GPU Nuclear concurs with the violation as stated.

Reason for Violation:

This violation occurred when a number ofindividuals failed to fully comply with GPU Nuclear procedural requirements. In addition, the governing corporate procedure did not contain this requirement while the implementing procedure for the Engineering Division contained the requirement.

Corrective Steps That Have Been Taken and the Results Achieved:

A prior self-assessment of the safety review process at Oyster Creek had identified a L number of strengths, good practices and opportunities for improvement. The opportunities for improvement included changes in process implementation and training.

The lack of consistency between the corporate procedure and the engineering implementing procedure and the level of compliance with the requirement to print one's name in addition to signing were both noted as areas of concern. A report concerning the self-assessment findings was widely disseminated to Oyster Creek management.

Corrective Steps That Have Been Taken To Avoid Further Violations:

l The corporate safety review procedure was modified in response to the recommendations of the self-assessment report. The effective date of the revision was March 6,1998.

Among the changes made was a revision to the safety determination and safety evaluation 1 forms requiring a printed or typed name in addition to a signature. The safety review  !

- training program was revised to reflect the changes and emphasize full compliance.  ;

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Date of Full C?mpliance:

. Full complianc; was achieved on March 6,1998 when the above noted revision to the Corporate Safety Procedure was modified. Training, which includes the procedure revision, ha. begun and is ongoing.

Violation C 10 CFR 50, Appendix B,- Criterion XVI, Corrective Actions, requires, in part, that:

" Measures shall be established to assure that conditions adverse to quality, such as failures, malfuncticas, deficiencies, deviations, defective material and equipment, and nonconfonnance are promptly identified and corrected.

Contrary to the above, on February 26,1998, a seismic deficiency with a containment spray heat exchanger, that had been identified in late 1996 by the licensee, had not been adequately corrected.

This is a Severity Level IV Violation (Supplement I).

Response

GPU Nuclear concurs with the violation as stated.

Reason for Violation:

During the USI A-46 walkdown of the Safe Shutdown Equipment List (SSEL) components in 1994, the containment spray heat exchanger chain hoists were written up as program outliers. The outliers pertain to seismic interaction between the chain hoists, which were hung unrestrained, and the heat exchanger tubing; valves and small bore piping. A Work Request (WR) was issued and a Job Order (JO) generated to resolve this outlier. The WR stated that the chain falls be removed or bagged but did not provide any specific guidance on execution of this activity. The bagging option was chosen, work was performed and the JO closed out on December 6,1996. Engineering was not notified of this closcout; hence, no engineering verification of this work was performed to verify that the potential seismic interaction hazard was removed. During January,1998, engineering reviewed the status of all SQUG outliers and determined that the subject JO was closed.

Engineering was in the process of scheduling the inspection for closcout of the outlier when the NRC site inspection found the chain hoist violation on the bottom side of the heat exchanger.

The bagging option from the WR was chosen and was performed on the hoists above the heat exchangers only. On the underside, the hoists were tied to the heat exchanger, which L is not in accordance with the WR and JO. The deviation from the JO without notification

!' is the cause for this violation.

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Corrective Steos Taken and the Results Achieved:

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Plant Maintenance was tasked to restrain all hoists and associated chain falls away from plant components. Engineering was tasked to review the final configuration for seismic verification to ensure the restrained hoists do not pose a potential seismic interaction hazard to any existing plant component and to justify any seismic interaction hazard that may exist.

Corrective Steps That Will Be Taken To Avoid Future Violations:

These hoists are used only during maintenance activities penaining to the containment spray heat exchangers. The maintenance activities are controlled by GPU Nuclear Procedure 2400-SMM-3214.02, " Containment Spray Heat Exchanger Cleaning and Assembly." This procedure has been revised to Revision 8 to include controls on storage of chain hoists upon assembly of the heat exchangers. The configuration described in the procedure matches the current verified configuration. Compliance with this procedure will ensure that the violation will not be repeated.

The Date When Full Compliance Will Be Achieved:

Full compliance was achieved on April 27,1998, which is the effective date for Revision 8 to procedure 2400-SMM-3214.02.

Violation D 10 CFR 50.59(b)(2) requires, in pan, that licensees submit a report containing a brief description of any cha.iges, tests and experiments (CTE), including a summary of the safety evaluation of each, annually or along with the UFSAR updates as required by 10 CFR 50.71(e) or at such shorter intervals as may be specified in the license.

Contrary to the above, as of March 12,1998, GPUN did not submit a CTE report for 1983 and 1986 for Oyster Creek Nuclear Generating Station, and the report submitted on February 16,1998, covered a period of April 1993 to March 1995.

This is a Severity Level IV violation (Supplement I).

ResD0nse:

GPU Nuclear concurs with this violation as stated.

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Reason for the Violation:

GPUN implemented 10CFR50.71 in 1983 and at that time began submitting the summary i 10CFR50.59 report following preparation of the FSAR annual update. Following the NRC rulemaking that allowed FSAR updates to be submitted on a schedule consistent with the refueling cycle, GPUN adopted the two-year update interval based on the 24 month refueling cycle. At this point, it was thought the 10CFR50.59 summary report could also be updated on the two year cycle but it was not recognized the report was required to be submitted with the FSAR update or submitted annually instead.

A additionally, the submittal of the report was mt captured in department work tracking processes to assure timely preparation and submittal.

Corrective Actions Takqq A review was conducted of all reports made since 1981 through 1998 to ensure the information required to be submitted during this time frame has in fact been submitted.

The information required to be reponed by 10CFR50.59 has been included in various reports,' although not on the required schedule, except for the information for the period March 1995 through December 1996. This report is currently in preparation and corresponds to the last update of the FSAR submitted in June of 1997. This report will be submitted by June 15,1998 and will establish fu'.! compliance with the regulations.

Actions to Prevent Recurrence:

The scheduled preparation and submittal of the 10CFR50.59 report has been revised to coincide with the submittal of the FSAR update following completion of the refueling outage for each cycle. Administrative functions and processes will be revised to establish appropriate tracking milestones and notifications to responsible individuals which will assure timely development and submittal in the future.

Date when Full Comoliance Will Be Achieved:

Full compliance will be achieved upon submittal of the next 50.59 report which is currently scheduled for the end of June,1998.

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