IR 05000219/1986006: Difference between revisions

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{{Adams
{{Adams
| number = ML20197H468
| number = ML20207J582
| issue date = 05/08/1986
| issue date = 07/24/1986
| title = Insp Rept 50-219/86-06 on 860303-0413.Violations Noted: Failure to Maintain Procedure Per NUREG-0612 Re Movement of Heavy Loads & to Follow Design Review Process Procedures. Annual Emergency Drill Deemed Acceptable
| title = Ack Receipt of 860624 Ltr Denying Violation Noted in Insp Rept 50-219/86-06 Re Assignment of Individual as Preliminary Engineering Design Review Chairman Not Independent of Engineering of Design Package.Violation Valid
| author name = Blough A
| author name = Starostecki R
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| addressee name =  
| addressee name = Fiedler P
| addressee affiliation =  
| addressee affiliation = GENERAL PUBLIC UTILITIES CORP.
| docket = 05000219
| docket = 05000219
| license number =  
| license number =  
| contact person =  
| contact person =  
| case reference number = REF-GTECI-A-36, REF-GTECI-SF, RTR-NUREG-0612, RTR-NUREG-612, TASK-A-36, TASK-OR
| document report number = NUDOCS 8607290177
| document report number = 50-219-86-06, 50-219-86-6, IEB-80-16, IEC-79-12, IEC-80-10, IES-79-12, NUDOCS 8605190174
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| package number = ML20197H402
| page count = 2
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 26
}}
}}


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U. S. NUCLEAR REGULATORY COMMISSION
JUL 2 41986 Docket No. 50-219 GPU Nuclear Corporation ATTN: Mr. P. B. Fiedler Vice President and Director Oyster Creek Nuclear Generating Station P. O. Box 388 Forked River, NJ 08731 Gentlemen:
Subject: Inspection 50-219/86-06 In your letter of June 24, 1986 regarding our inspection report 50-219/86-06, you took issue with Violation B(2). This matter has been brought to my atten-tion because you stated that you did not agree with the violation.


==REGION I==
This matter involved the assignment of a Preliminary Engineering Design Review (PEDR) Chairman for the 480 volt vital transformer cooling fan modification, BA402786, who was not independent of the engineering or managing of the design package as required by Technical Functions Division Procedure EMP 014, Project Reviews. In your response you stated the detailed engineering for this project was assigned to General Electric and, as such, the responsible GPUN manager was not directly responsible for managing the engineering details and, therefore, was eligible to function as the PEDR Chairman. EMP 014 clearly states the PEDR Chairman in the capacity as the Responsible Technical Reviewer (RTR) "shall not have been involved in engineering or managing the design." In this case the PEDR Chairman was responsible for and involved in managing the design of BA402786. Although we recognize that the individual may not have been involved in the " engineering details" as indicated in your response, our view is that the intent of the procedure is to obtain a separate overview of the matter.
Report N /86-06 Docket N License N OPR-16  Priority --
Category C Licensee: GPU Nuclear Corporation 100 Interpace Parkway Parsippany, New Jersey Facility Name: Oyster Creek Nuclear Generating Station Inspection At: Forked River and Parsippany, New Jersey Inspection Conducted: March 3 - April 13, 1986 Participating Inspectors: W. H. Battman, Senicr Resident Inspector J. F. Wectselberger, Resident Inspector W. H. Baurack, Project Engineer Approved by:
l>J OmA 4 A. R. Blough, Chief f rNrt Da'te Reactor Projects Section in Inspection Summary:
Routine inspections were conducted by the t-esident inspectors and a Region based inspector (373 hours) of activities 1.1 progress including plant opera-tions, physical security, radiation control, housekeeping, fire protection, emergency preparedness, and outage preparations. The inspectors also reviewed ,
licensee action on previous inspection findt'.igs, made routine tours of the '
facility, participated as observers in the annual emergency drill, observed licensee action during an Unusual Event declared as the result of a bomb threat, and reviewed the most recent licensee QA environmental qualification audit. In addition, the inspectors visited the GPUN corporate offices and met with various members of Tech Functions management and also reviewed four modification packages scheduled to be implem:nted during the 11R outag The inspectors also attended several briefings i.cluding the QA Annual Assessment, inservice inspection plans for the 11R outag.., PSMS computer system, and the Maintenance, Construction, and Facilities' Werk Management Syste PDR ADOCK 05000219 G  PDR R


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It is not clear by your response as to how this separate review was accom-plished. In our view the assigned individual was ineligible to perform the RTR function.
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Results:
Two violations were identified. One involved failure of Plant Engir.eering (PE)
to maintain the station procedure governing their conduct as described in para-i graph 1, as well as failure of PE to properly prioritize and address a licensee self-identified concern regarding failure to address NOREG 0612, movement of heavy loads, at the Intake Structure as described in paragraph 2; and the other f involved failure of Tech Functions to follow procedures governing the design review process as discussed in Paragraph Plant response to the bomb threat was comprehensive. The annual emergency drill was termed acceptable. Plant operations were interrupted twice -- once due to an unexpected reactor trip and once due to an unplanned shutdown to replace reactor low water level scram sensor I At the end of the report period, the plant was shutdown and the 11R outage had Commence ,
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We have evaluated your response and have reviewed again our original findings, concluding the citation is valid. Accordingly, you are required to respond within 20 days of the date of this letter. Your response should explain what corrective steps will be taken to assure that both the intent and spirit of independent review is not compromised.
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Details


1. Licensee Action on Previous Inspection Findings  l (Open) Inspector Follow Item (219/84-06-02): Closecut Documentation for Plant Material (PM) Department Plant Engineering Work Requests (PEWR)
Thank you for your attention in this matter.
Not Always Available During NRC Region I Inspection 84-06 it was noted that closeout documen-tation of PM PEWRs was only occasionally available, there was a lack of status of PEWRs, and a lack of understanding of the priorities for open requests. These factors were discussed with plant management who indi-cated that the matter would be reviewed and appropriate action take During this inspection those actions taken by the licensee to resolve this item were reviewe The PM Department, by memorandum dated January 9,1985, notified Plant i Engineering (PE) of open PM PEWRs. Also, all outstanding PEWRs were reviewed and those considered no longer applicable were cancelled. The PM Department has setup a program establishing a central departmental contact for liaison between PE and P All PEWRs are to be handled and tracked by this contact. PM, by memo-randum dated June 19, 1985, also requested from PE all acknowledgements of acceptance of PEWRs, all completed PEWRs, and any correspondence with regard to PM PEWR Based on these actions the licensee's Licensing Action Item written to resolve this matter was close To verify the effectiveness of the licensee's actions, the PM PEWR log was l
reviewed by the inspect 6r. This log indicated 30 no longer applicable open PEWRs had been cancelled, 19 PEWRs have been closed, and 115 remain open. Of the open PEWRs, 36 were written in 1983, 32 in 1984, 43 in 1985, and 3 in 1986. Some open items indicated acknowledgements from PE, however, many are logged with no acknowledgements indicate The inspector selected 22 of the items identified in the log as still open for follow-up in the PE file Five of the items were found to have been closed in PE files. Two of these five had documentation indicating PM had been informed of the closeout. Four of the items were closed by PE-by Technical Functions Work Requests, the status of these items was not tracked by PE, and PM was not notified of this'closecut. The status of these items was not tracked by PE. Eleven were indicated as open in PE files. Information relative to two items was not readily available and no follow up of these was conducted. Due to the fact.that some errors still appear to exist in the PM documentation relative to PEWRs, this item 84-06-02 remains ope ;


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Sincerely, Original S1 8ued By:
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Richard W. Starostecki, Director Division of Reactor Projects ag72h77860724CK0500g ;ICIAL RECORD COPY RL OYC 86-06 - 0001.0.0
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  $    07/23/86 160I h
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. 3 Because of the discrepancies noted between PM and PE files, particularly after an effort had been made to improve tracking of PM PEWRs as a result of NRC Inspection 84-06, the inspector reviewed Station Procedure Number 125, Conduct of Plant Engineering , as it related to tracking of engineer-ing tasks. This procedure was written to delineate the functions, respon-sibilities, authorities, and organizational interfaces of the PE organi-zation. A review of this procedure indicated the procedure had become outdated in a number of areas. These areas include:
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Organization: the procedure describes an organization different than the organization that currently exists. Consequently, the proce-durally described responsibilities are for position titles which do not exist. How these responsibilities are performed within the existing organization is not clea Performance of engineering tasks: the current method of initial review of work requests and the issuance of Plant Engineering Task Assignments (PETA) differs from that described in the procedur Copies of PETAs are not always forwarded to the requestor as require Also, close-out of PETAs is not always as procedurally required in that Form 125-2 is not generally completed in closing-out PETA This form requires a close-out response be provided to the originato Records maintenance differs from that described in the procedur The prioritization of PETAs differs substantially from that described in the procedure. The PE procedure identifies only two priority classifications. The actual prioritization is done basically in ac-cordance with a Technical Functions Division procedure which results in numerous priorities. PM personnel were unaware of the meaning of the priority numbers assigned to their item The PEWR form being used differs slightly from that attached to the procedure. In addition, there are no instructions in the procedure detailing how this form is to be used, particularly,'the acknowledge-ment sectio The above are examples of the more significant deficiencies noted in the Conduct of Plant Engineering Procedure. These and other procedural problems were discussed in detail with the PE-and PM Directors. The in-spector noted the failure to maintain the Conduct of Plant Engineering Procedure current was considered to be a violation (219/86-06-01). The PE Director indicated a forthcoming reorganization and the change-over to a new computerized Action Item Tracking System were th> reason the pen-cedure was allowed to become outdate .


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  . 4 It should be noted only the portions of the Conduct of Plant Engineering Procedure dealing with performance of engineering tasks were reviewe Other portions of th'e procedure may also be outdate (Closed) Inspector Follow Item (219/84-06-0E): Licensee to revise diesel generator procedure to include certain check The licensee has revised Station Procedure 636.4.003, Diesel Generator Load Test, to include verification of filter oil level, verification of
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; DG battery strip heater energization, and acceptable level for DG fuel oil day tank.
GPU Nuclear Corporation 2 cc w/ encl:
 
M. Laggart, BWR Licensing Manager Licensing Manager, Oyster Creek Public Document Room'(PDR)
I (Closed) Inspector Follow Item (219/84-06-03): Plant Materiel mechanical section to provide equipment failure review to the Vice president and Directo The Plant Materiel mechanical section has established a Plant Materiel Mechanical Equipment Trending Progra Part of this program is to provide a quarterly report to the Deputy Director. In addition, a year end summary is also provided the Deputy Director. The year end summary summarizes trends, failures, corrective, and preventive maintenance performed by system and by individual components. The report also describes problems and experiences and proposes corrective action (Closed) Inspector Follow Item (219/83-25-01): Licensee audit finding identified inconsistencies in radiation protection procedure A subsequent Quality Assurance Audit S-0C-84-17 performed by the licensee from October 22, 1984 to January 2, 1985 of radiological controls deter-mined, based upon a review of the 900 series procedures, all previous discrepancies have been corrected. In addition, a major rewrite of the
Local Public Document Room (LPDR)
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Nuclear Safety Information Center (NSIC)
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NRC Resident Inspector State of New Jersey Lcc w/ encl:
radiation controls procedures was conducted in 1985. During this rewrite many outdated procedures were delete .( Closed) Unresolved Item (219/83-24-02): Inaccurate response to IE Bulletin 80-1 Inspection 83-24 identified the installation in the plant-of certain trans-mitters which the licensees response to IE Bulletin 80-16 indicated were not used at Oyster Creek. The licensee committed to certain corrective actions. These included (1) a review of the respense to IE Bulletin 80-16 and the submittal of corrections to the Bulletin response dated July 24, 1980. This was accomplished by licensee letter Fiedler to Murley, dated November 9, 1982; (2) an audit of IE Bulletins and GE Service Information Letters (SILs) to assure licensee actions and statements reflect the con-ditions at the plan Licensee Action Item files 83023.02 and 8006 contain memoranda which show that these audits have been performed; and (3) a system will be developed to inform all potential users of the impact of IE BC.letins and GE SILS to avoid further use of defective component The licensee has in place Corporate Procedure 1000-ADM-1216.03, Regulatory Correspondence Control, which defines and establishes the GPUN system for  ,
Region I Docket Room (with concurrences)
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Management Assistant, DRMA (w/o encl)
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Section Chief, DRP Robert J. Bores, DRSS f / Bateman RI:DRP 9: RI DRP Blough dRI*.DRP Kister R;;DP Starostecki 07/ 17/86 07/G/86 07d86 07g986 0FFICIAL RECORD COPY RL OYC 86-06 - 0002.0.0 07/23/86
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GPU Nucioer Corporation
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NQQIgf    Post Office Box 388 Route 9 South Forked River.New Jersey 087310388 609 971 4000 Wnter's Direct Dial Number:
June 24, 1986 Mr. Harry B. Kister, Chief Projects Branch No. 1 U.S. Nuclear Pegulatory Connission Region I 631 Park Avenue King of Prussia, PA 19406
 
==Dear Mr. Kister:==
Subject: Oyster Creek Nuclear Generating Station Docket No. 50-219 IE Inspection Report 86-06 Attachments to this letter provides GPU Nuclear's responses to the identified violations in Appendix A of your letter dated May 12, 1986. As receipt of this report was delayed 9 days, an extension of the due date to June 25, 1986 was granted by the Resident Inspector at the Oyster Creek Station.


the management of incoming and outgoing regulatory correspondence and the assignment of tasks associated with that correspondenc [ Closed) Unresolved Item (219/80-25-03): Review drain time difference of scram discharge volume (SDV) following two successive scram During Inspection.80-25 a significant difference was noted in the time for the SDV to drain following an automatic scram and a manual scram (161 sec. vs. 84 sec.). During the last outage, major modifications were made '
If any further information is required, please contact Mr. John Rogers of ray staff at (609)971-4893.
to the SDV system. The existing SDV which had experienced the drain time difference has been removed and replaced with two separate SDVs. During startup testing following the modification, SDV drain times were recorded and no abnormal drain times were note (Closed) Unresolved Item (219/80-09-01): This item deals with the sealing of electrical connections to limitorque valve operators within the drywel During NRC Region I Inspection 80-09, several concerns were noted. One
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concern dealt with a flexible electrical conduit pulled from its packing gland on the solenoid actuator for reactor water sample isolation valve V-24-29, and the other with the sealing of motor operated valve operator cable where it exits rigid condui Quality Control Inspection Report 11085 verified that the flexible 1 electrical conduit associated with V-24-29 had been repaired. Also, the licensee performed an evaluation of motor operated valves which might experience infiltration of steam under accident conditions through cable exiting rigid conduit. Two valves were identified V-14-36 and 37 for which sealing at the conduit leading to the valve was recommended. These conduits were sealed per Job Order 0450 (Closed) Licensee Identified Items (219/81-LO-3E, 81-LO-4E, 81-LO-5E, 81-LO-6E, and 81-LO-7E).


These items deal with Nonroutine Environmental Operating Reports which were submitted by the licensee. The first four deal with less than the required number of dilution pumps operating and the last deals with exceeding the allowable temperature difference between circulating water intake and discharge due to grass clogging of the intake ,
Very truly yours,
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1.g P iedler V e President and Director l    Oyster Creek
; PBF/JR/ dam
! Attachments l cc: Dr. Thomas E. Murley, Administrator
)  Region I
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By Amendment No. 66 to the Oyster Creek Operating Licensee issued on I
U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Mr. Jack N. Donohew, Jr.
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May 24, 1983 the non-radiological water quality-related requirements were )
deleted from the Environmental Technical Specifications. ' Consequently, i this type of event is no longer required to be reported to the NR '
 
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As a followup to these reports, the inspector verified that certain improvements have been made to the dilution pumps. These improvements include changes to the pump seal water and lubricating oil cooling water, upgrading of piping to more corrosive-resistant material, extensive pump
f  U.S. Nuclear Regulatory Connission l
7920 Norfolk Avenue, Phillips Bldg.


maintenance, and the stocking of spare parts. Additional modifications to improve dilution pump performance are planned for the 1986 refueling outage. Also, limits associated with the main condenser _ circulating water system and the thermal dilution pumps are contained in Station Procedure 323, Main Condenser Circulating Water System, and Procedure
l Bethesda, MD 20014 l
  , 324, Thermal Dilution Pumps, respectivel (Closed) IE Circular No. 80-10 (219/80-CI-10): Failure to maintain environmental qualification of equipmen This Circular described several instances in which environmental qualification of equipment was not maintained due to the use of the wrong class of equipment during maintenance. The Circular recommended licensees review maintenance procedures and administrative policies to ensure: (1)
c NRC Resident Inspector
adequate administrative controls exist to ensure that equipment which is environmentally qualified is identified prior to maintenance; (2) mainte--
! Oyster Creek Nuclear Generating Station l
nance procedures provide necessary instructions and precautions to ensure that the environmental qualification of equipment is not degraded when maintenance is completed; and (3) maintenance personnel are adequately trained on environmental qualification requirements and the potential for r
! -8vo707003 V GPM Nuclear Corrgoration is a subsidiary of the General Public Utilities Corporation
equipment degradation from improper
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maintenanc The licensee has in effect Station Procedure No. 105.3, Maintenance of Oyster Creek Environmental Oualified (EQ) equipment. This procedure has been prepared to provide administrative control and practices related to all maintenance performed on EQ equipment and to assure that procurement
; of replacement components is in accordance with EQ requirements. The procedure specifies training of maintenance planning personnel on requirements to maintain EQ and incorporates appropriate requirements in tasks on EQ equipment. Also, the procedure requires that maintenance personnel be trained on requirements to maintain EQ. The inspector verified planners received the required training on September 18, 1985, and the maintenance personnel on September 9, 198 . Control of Movement of Heavy Loads at the Intake Structure A review of outstanding Plant Engineering Work Requests (PEWRs) disclosed a situation wherein a safety concern was identified and submitted to Plant Engineering (PE) for action that PE had failed to address. In particular, a PEWR initiated by Plant Materiel dated 8/19/85 explained that heavy loads were being moved at the Intake Structure using a mobile crane in the vicinity of safe' shutdown equipment (four Emergency Service Water. pumps) without procedural controls. The PEWR requested that the
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movement of heavy loads at the Intake be analyzed to ensure NUREG-0612 (Control of Heavy Loads) guidelines are met. The NRC inspector determined that the licensee's response to the NUREG-0612 guidelines for the Intake stated that since the gantry crane at the Intake had been removed from
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  -         ATTACHMENT I Violation A:
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Technical Specification 6.8.1 requires that written procedures shall be established, implemented, and maintained. Station Procedure 125, Revision 2, Conduct of Plant Engineering, delineates the functions, responsibilities, authorities, and organizational interfaces of the Plant Engineering organization. Paragraph 6.4 of this procedure requires that Plant Engineering tasks be prioritized and those tasks deserving issnediate attention assigned a priority one rating. The procedure requires, in part, that a priority one rating be given to thoses tasks which, left undone, would cause a NRC commitment deadline to be missed.
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  -   7 service the Intake was excluded from NUREG-0612 applicability. The
; responte also said, "If at some time in the future this crane is placed back into service, an evaluation will be performed to ensure that NUREG-0612 criteria are satisfied." The response did not recognize nor
; address the use of a mobile crane to move heavy loads at the Intake. The Plant Materiel group-who identified the issue exhibited a good awareness of regulatory commitments and onsite condition PE received this PEWR on 8/20/85, assigned it PE Task #512200850635, and A
gave it a priority 2 rating. Paragraph 6.4 of Station Procedure 125, i
Conduct of Plant Engineering, Rev. 2, discusses management of PE tasks and requires, in part, that tasks which, left undone, would cause a NRC
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commitment deadline to be missed, should be given priority 1 ratin ; Although procedure 125 does not explain the significance of a priority 1 j rating, it is implied that priority 1 demands immediate attention. The
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anticipated completion date for this task was listed as 1/1/99, which by PE definition meant it was unscheduled. The failure of PE to assign the appropriate priority rating to this PEWR resulted in a nuclear safety issue not being promptly addressed. This is a violatio (219/86-06-02)
1 Subsequent to identification of this matter by the NRC inspector, the licensee committed to cease movements of heavy loads at the Intake until
; the appropriate evaluations and training are complete . Surveillance Testing In Inspection Report 86-04, a summary of events relating to the erratic performance of Static-0-Ring (SOR) differential pressure sensors was -
presented. During this report period, the erratic. performance continued
, and a licensee decision was made to shutdown the plant and replace.the a reactor low level scram sensors with a slightly different model tisat had been performing satisfactorily as the reactor low low level sensors. ' SOR l model number 103 AS-8212-NX-JJTTX6 was replaced with SOR model number 103
, AS-BB212-NX-JJTTX6 and some minor modifications were made to the sensor's
! inlet piping. The sensor replacement and piping changes were classified i as a modification and received a safety evaluation.


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(1) Contrary to the above, as of April 3,1986, Station Procedure No.


.Weekly surveillance of the new sensors was implemented following plant l
125 was not being maintained, as it relates to the tracking of engineering tasks. Significant discrepancies existed between procedural descriptions and requirements and the way the Plant
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startup. Problems with setpoint drift of these sensors was also exper-tenced and one. sensor was undergoing daily surveillance the week prior to plant shutdown for the 11R outage. Neither the licensee nor SOR have.an explanation for the setpoint drift. At one point it was suspected a valving sequence to verify reactor vessel communication (referred to as
Engineering organization was conducting activities. These discrepancies included the following areas: (1) description of the organization and responsibilites; (2) the performance of engineering tasks, including the initial review and assignment of engineering tasks, acknowledgement to the requestor, and the close out of tasks including response to the requestor; (3) the maintenance of records; and (4) the prioritization of plant engineering task assignments.
" bang test") was the cause. However, subsequent evidence has eliminate this possibility. The licensee's present plans are to replace the low l level scram sensors with an analog type-system during the 11R outage and
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to delay replacement of other plant sensors that were scheduled to be replaced with SOR unit '
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(2) Contrary to the above, as of April 4,1986, Station Procecure 125 l
other site locations including the site boundary with negative result Operations corrected the problem by reestablishing a negative differential pressure in the turbine buildin During routine surveillance by radcon of trash in dumpsters outside the RCA, a slightly contaminated piece of an old LPRM box was identified. A spot the size of a silver dollar was found to read 200 cpm above backgroun The LPRM box was being cut up for disposal and the radiologically clean pieces were disposed of as clean trash. Radcon management discussed the
was not adequately implemented, in that a Plant Engineering Work Request written August 19, 1985 by the Plant Materiel Department
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inadequate survey with the technician-involved and counseled the individual as to the importance of a thorough surve The licensee discussed their man rem exposure goals for 1986 with the NRC 1 inspectors. The estimates include outage related exposure. The man rem ,
j estimate for 1986 without decon of the recirc piping is approximately '
1700. The licensee plans, however, to decon the recirc piping thereby r2ducing the estimate to 1000. A goal of 800 has been se It is note-1 worthy that the chemical decon of the recirc piping will reduce personnel exposure by approximately 40 man rem per wee The investment by the licensee to reduce personnel exposure is noteworth . Operational Safety Verification 6.1 Control Room Safety Verification i Routinely throughout the inspection period, the inspector indepen-dently verified plant parameters and engineered safeguard equipment i availability. The following items were observed:
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Adherence to approved procedures for ongoing activities;
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and received by P.lant Engineering on August 20, 1985, had been
Proper safety systems and emergency power sources valve and breaker alignment; and
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given a priority two rating and was not scheduled for review. The
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Shift turnover.
issue involved lack of plans and procedures governing movement of
 
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! 6.2 Review of Logs and Operating Records
heavy loads (NUREG-0612) using a portable crane at the intake structure in the vicinity of the emergency service water pumps. A Safety Evaluation, in part, documenting the licensee's consnitments regarding movement of heavy loads, was issued June 21, 1983. In this document it was explained that movement of heavy loads at the intake was not a concern because the intake gantry crane had been
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The inspector reviewed, on a sampling basis, the following logs and
, instructions for the period March 3 to April 13, 1986:
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removed but that, if at some time in the future this crane is placed back in service, an evaluation would be performed to ensure that NUREG-0612 criteria are satisfied. Although the gantry crane has not been placed in service, the use of a portable crane to move heavy loads is an equivalent situation.
Control Room and Group Shift Supervisor's Logs;
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Control Room and Shif t Supervisor's Turnover Check Lists; j
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Reactor and Turbine Building Tour Sheets; i
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The inspectors considered the licensee's efforts to address the problem of setpoint drift of the reactor low level scram sensors to be sound in engineering judgement and conservative regarding safe plant operatio . Review of QA Audit of Environmental Qualification The licensee's QA group performed an audit of the environmental qualifi-cation of electrical equipment at Oyster Cree The audit number was
Response:
, 0-0C-85-08 and was performed November 11-26, 1985. Because of concerns raised during discussions with QA management regarding changes to the audit after initial issue, the inspectors decided to review the audit to ensure the changes made did not impact the audit findings. A comparison of the initial issue of the audit with the final issue indicated that two subjective statements had been deleted but that the audit recommendations were unchanged. The NRC inspector did not feel the deletion of the GPUN QA auditor's opinions from the audit detracted from the effectiveness of tne audit, especially in light of the fact that the audit's final con-clusicns remained unchanged. The NRC inspector did, however, request that he be informed when Tech Function's Engineering Assurance responds to the audit recommendations. The inspector will review the responses during a subsequent inspectio (219/86-06-03)
      (1) GPUN concurs in the violation.
5. Radiation Protection During entry to and exit from the RCA, the inspectors verified that proper warning signs were posted, personnel entering were wearing proper dosimetry, personnel and materials leaving were properly monitored for radioactive contamination, and monitoring instruments were functional and in calibration. Posted extended Radiation Work Permits (RWPs) and survey status boards were reviewed to verify that they were current and accurat The inspector observed activities in the RCA'to verify that personnel complied with the requirements of applicable RWPs and that workers were aware of the radiological conditions in the are As a result of the reactor trip on March 6, 1986, 8 people working in the turbine building became slightly contaminated with short-lived radio-isotopes (cesium 138 and rubidium 88). The turbine building became slightly airborne when sealing steam was lost to the turbine gland seal The contamination was not an unexpected event. The maximum level.was 1500 cpm on a worker's hard hat. Radcon response to the contamination problem was prompt and thoroug On March 21, 1986 water vapor was observed escaping from around the roof plugs on the turbine building heater bay roof. Because the heater bay contained airborne contamination from valve and equipment leakage, radcon was promptly notified whereupon they sampled the space above the heater l bay roo Results of one sample indicated a minor unmonitored release . ;
was in progress. Immediate action was taken by Operations to correct the problem. Additional samples were taken above the heater bay roof and at i
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Insnediate corrective action was taken to initiate a revision to Procedure 125. The requisite organizational description and j
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delineation of responsibilities were revised and clarified. The engineering request tracking system description was updated to more i
 
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Equipment Control Logs;
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Standing Orders; and
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Operational Memos and Directive ;
The logs and instructions were reviewed to:
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Obtain information on plant problems and operations;
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Detect changes and trends in performance;
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Detect possible conflicts with Technical Specifications or regulatory requirements;
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Assess the effectiveness of the communications provided by the logs and instructions; and
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Determine that the reporting requirements of Technical Specifications were me , The reviews indicated the logs and operating records were generally comple'.e. No inspector concerns were identifie .3 Review of Key Events 2 Reactor Scram On March 6, 1986 the facility experienced a reactor trip due to a spurious turbine stop valve closure signal that occurred during routine turbine stop valve surveillance testing. Approximately one minute after the trip, the MSIVs isolated due to reactor pressure decreasing to less than 850 psig with the Mode switch
; still in RUN. At nearly the same time, the Reactor Water Clean-up (RWCU) System isolated. Electromatic relief valves were manually actuated to control pressure until reactor water level was brought back into the indicating range at which time the isolation condensers were used to control pressure. Several minor airborne contamination problems resulted in the turbine building and minor flooding occurred in the steam jet air ejector room due to an already leaking gland seal exhauster condense _
1 The exact cause of the scram was subsequently determined to be
. a malfunctioning of the position switch on the No. I turbine
{ stop valve (TSV). ~Specifically, the contacts on the open posi-
.
tion switch were not making continuously. Similar-switches on the other TSVs were checked and verified to be functional. The No. 1 TSV position switch was replaced.
 
,
k
 
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The plant equipment response was as expected with the only significant exception that a RWCU system containment isolation valve, V-16-14, failed to cpen during one of several cycle Follow-up testing of V-16-14 to identify the problem did not indicate a cause. The NRC inspector further pursued this matter subsequent to plant restart and was informed by PE that it has been known for some time that the valve motor is -
slightiy undersized for the valve opening operation. (Note:
The valve closing function is safety-related, but opening is not.) Previous problems with operability of this valve resulted in making a Limitorque gearing change in an attempt to correct the problem. The licensee has stated the problem with V-16-14 will be corrected prior to restart from the 11R outag Operator response to the trip indicated that past problems with reactor water level control during trips has become a major operator concern. As a result, during this trip recovery, the control room operator gave his primary attention to control of water level and neglected to place the Mode Selector switch to SHUTDOWN. Within one minute of the trip, plant pressure had decreased to less than 850 psig and, with the Mode switch still in RUN; a MSIV closure occurred. The closure of the MSIVs i added additional complications to the scram recovery in that the EMRVs and the Isolation Condenser system had to be used for heat sink purposes. A review of Station Procedure 2000-ABN-3200.01, Rev. O, Reactor Scram, indicated the first two steps an operator should perform after an automatic trip are to depress both manual scram pushbuttons and place the Mode switch to SHUTDOWN. However, this procedure is prefaced by the statement, "If while executing this procedure, any entry condition for any Emergency Operating Procedure (EOP) occurs, Then immediately exit this procedure and enter the appropriate E0P." One of the peculiarities of Oyster Creek is that a low level scram signal is received each time a scram occurs. This is a genuine signal and demands immediate entry into the level control E0P. This E0P does not address the initial steps required by the reactor scram procedure. During past trips operators have properly positioned the Mode Selector switch but this time it was overlooked due to concerns for water level control. The inspector reviewed the licensee's Post Trip Review of this event and noted that the failure of the operator to reposition the Mode Selector switch was a major concer The licensee committed in their Post Trip Review to evaluate operator priorities following reactor trips and to make any necessary procedural changes. The inspectors will follow up licensee actions in a subsequent inspection. (219/86-06-04)
B. Some problems occurred during the subsequent restart from the 3/6/86 reactor tri Instrumentation associated with th 'C'
EMRV indicated seat leakage. The licensee operated the .lve several times in an attempt to reseat i The attempts were
    '
  ..  . .,  -  - -- -
 
_ __
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. 12 not successful and the plant continued to operate until shutdown for the 11R outage with minor seat leakage past the 'C'
EMR Instrumentation associated with the 'D' and 'E' EMRV in-dicated they were also experiencing minor seat leakage through-out the remainder of the operating cycle. The EMRVs are scheduled for overhaul during the outag During one of the attempts to reseat the 'C' EMRV, the plant nearly experienced a reactor low level scram. Prior to lifting an EMRV the reactor water level control system is placed in manual to preclude the system response that would occur if control was in automatic. If left in automatic the swell caused by lifting the EMRV would signal the control system to throttle down feedwater flow. This action, combined with a greater feed flow / steam flow mismatch, would result in a rapid decrease in reactor water level. What apparently occurred during this attempt was a malfunction of the level control
: switch such that, although the switch was in the manual position, the contacts remained in automatic. The result was a rapid decrease in reactor water level and a half scram signal caused by low reactor water level. This switch problem and other problems with the Mode Selector and IRM Range switches caused the inspector to express a concern regarding operator confidence in operation of these switche Plant management plans are to replace the Water Level Control switch and modify the IRM Range switch prior to restart from the 11R outag Actions are also underway to purchase a new Mode switch, although it is uncertain whether it will be installed prior to restar C. Throughout the latter portion of the operating cycle, leakage of condensate from the gland seal exhauster condenser caused problems. Each time plant load was reduced, condensate header pressure increased making the leakage worse, thereby, causing erratic operation of the gland seal exhaust fan Plans are to repair the condenser during the outag D. During performance of augmented surveillance of the reactor low level sensors, an ECCS initiation occurred. The initiation signal was generated when one of the sensors was being valved back into service following surveillance. The licensee deter-mined that a slight flow surge and pressure drop in the variable leg occurred when a test gauge, used to confirm sensor communi-cation with the reactor vessel, was valved in. This variable leg also serves the reactor low low water level sensors. The filling of the empty tubing between the isolation valve and the gauge caused the transient. This transient was sensed by the reactor low low level sensor which in turn initiated the ECCS signal. Two Core Spray main and booster pumps started, both emergency diesel generators started, and one half an ATWS trip
:
 
    . . . -   _ . .
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.
 
signal occurred. All systems responded normally and the oper-ators recovered from the event without incident. No actual ECCS injection to the vessel occurred. The surveillance proce-dure was subsequently modified to require filling the tubing between the isolation valve and the gauge prior to opening the isolation valv As mentioned in paragraph 5 above, an unmonitored release of radioactivity occurred from the turbine building heater bay roo f. This rerulted because of gradual degradation of turbine building exhaust fan 1-7 and subsequent positive pressurization of the turbine building. Operator response to correct the problem was prompt. However, follow-up as to why the gradual change in turbine building to atmosphere differential pressure (d/p) from nep tive to positive was not detected, disclosed that the control room instrumentation for this d/p was out of service and the local instrumentation in the turbine building was not logged and reviewed. The inspector suggested to the licensee that when control room instrumentation is taken out of
 
service that compensatory action be taken to log and review readings from local instrumentation. The licensee agree . Scram Reduction Task Force Based, in part, on the above average number'of plant scrams in 1985, the licensee formed a scram reduction task force to investigate causes of trips and make recommendations for reducing plant trips. The task force issued a document entitled "0yster Creek Scram Experience" (TDR 724). The inspectors reviewed this document to ensure the conclusions reached en-ccmpassed their concern for balance of p' ant impact on the primary sid The document analyzed all plant trips from January 1976 to December 198 There were a total of 35 scrams during this period. The 6 trips experi-enced in 1985 were only exceeded by the 7 trips in 1979. Of the 6 trips in 1985, 4 were attributed to equipment failure and 2 were considered human related. This is in contrast to 1979 when only one was considered equipment failure and 6. human related. An analysis of all 35 trips indi-cated 40% of all scrams were due to human related causes while starting up or shutting down. Twenty-six percent were due-to human related causes while performing testing or maintenance activities, and the remaining 34%
were due to equipment failure, mostly in balance of plant systems. The nuclear industry has set a goal of no more than 3 unplanned trips per      *
i    plant year for plants with greater than 3 years operating experience. The
 
average for BWRs in 1984 was Oyster Creek was shutdown for all but 2 months of 1984 and experienced 2 trips during the 2 months of operatio The report was generally well done. Recommendationsweremadethatcould help in reducing the number of reactor trips. The statement was made that it was too early to determine if a trend existed regarding balance of plant equipment failures. Only one scram occurred during the first 3
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___________________________.__________.____.______.____ . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ . _ . _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ . _ _ _
 
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months of 1986 and it resulted from a balance of plant equipment failur The inspectors had anticipated the report would have recommended more intensive investigation of the potential impact of balance of plant components on plant operation. For example, there was no recommendation to investigate periodic replacement of equipment that interfaces with the
  .- -
; reactor protection system. This was discussed with plant management who i  stated that, even though this was not a specific recommendation of the report, it was being reviewed by Plant Materiel as a separate job actio The inspectors will follow up the review by Plant Materiel in a subsequent i
    -?-
inspectio , Review of Periodic and Special Reports Upon receipt, periodic and special reports submitted by the licensee pur-suant to Technical Specification requirements were reviewed by the inspec-tors. This review included the following considerations: the report in-cludes the information required to be reported to the NRC; planned corrective actions are adequate for resolution of identified problems;
  '
  '
and the reported information is vali The following reports were reviewed:
    .
i
accurately describe the system presently in place listing engineering requests and tracking them to completion. The requirements for records management were revised to align with GPUN commitments to ANSI Standards. The prioritization methodology was redefined and fonnally proceduralized.
  --
Monthly Operating Reports for January and February 1986
  --
Annual Exposure Data Report for 1985
;
  --
Second 1985 Semi-Annual Effluent Release Repor The effluent release report stated there were no releases of radioactive liquids during the perio No concerns were identified.
 
I Technical Function Division Inspection The inspectors made two separate visits to the GPUN Corporate Engineering t
offices in Parsippany, N.J.-during this report period. The first visit
,
"
involved meetings with various Tech Functions department managers to gain an understanding of the organization. The managers were all very helpful 1~
and appeared to have a comprehensive understanding of their department and interfaces with other departments. The spirit of cooperation experienced
 
during this visit contributed to helping the inspectors gain a rudimentary
.
understanding of the Tech Functions organizatio i
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L____ _ __ _ __ _ _ ______ _ _ _ _ _ _ _______ _ _ .__ _ ____ ________ ___ _ __ _ _ _ ___ _ ____ ____ ___ _ __ _ _ _ . _ _ _ _
 
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The second visit involved a review of the following four modification packages scheduled for work during the 11R outage:
  --
  .BA 328145 Reactor Head Flange Thermocouples
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BA 402207 Recirculation Valve Interlock
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BA 402775 Diesel Generator Lubrication System
  --
BA 402786 460V USS 1A2, 182 Transformer Cooling Fans l  The following Tech Functions procedures were referred to during the
'
package reviews:
  --
EMP-002, Mini-Mods, Rev. 0-00
  --
EMP-014, Project Reviews, Rev. 1-01
  --
EP-008, Control, Evaluation and Resolution of Review Comments on Technical Documents, Rev. 1-00
  --
EP-009, Design Verification, Rev. 1-00
  --
EP-016, Nuclear Safety / Environmental Impact Evaluation, Re I 1-00
  --
LP-009, Independent Safety Reviews, Rev. 1-00 The review of the modification packages included the aspects of environ-mental qualification and fire hazards analysis considerations, proper design review implementation, proper safety reviews, specification completeness, establishment of functional criteria, quality assurance considerations, and adherence to governing procedures. A summary of the review follows:
9.A The 460V 1A2 and 182 Transformer Cooling Fans (BA 402786) modifica-tion was initiated as a result of an electrical load study performed


at Oyster Creek. The study determined that the 460 volt 1A2 and 182 buses may be overloaded during a loss of coolant accident with off-site power available and a loss of either IA2 or 182. A licensee evaluation determined that the transformers' capacity could be in-creased by adding cooling fans. This was reported by LER 85-00 The following documents were reviewed:
Full compliance was achieved with the issuance of Revision 3 to Procedure 125 on June 13, 1986.
  --
Procurement Specification SP-1302-11-21R1
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Purchase Order (Reg. 5350-85-0158-001; P.O. No. PP-027569)
  --
Statement of Justification
  --
System Design Description I (0C-732A Rev. 0)
  (includes 50DII requirements)
  --
GPU drawings
  --
Nuclear Safety / Environmental Impact Evaluation (SE 4027862001)
  --
Preliminary Engineering Design Review (PEDR) comments Installation Specification (OCIS 402786-001)
'
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Fire Hazards Analysis The following concerns were identified as a result of the review:
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(2) GPUN concurs in the violation.
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The identified Plant Engineering Work Request (PEWR) was not evaluated in compliance with revision 2 of procedure 125 in effect at the time. However, the philosophy for prioritization had been modified, and a revision to procedure 125 had been initiated and was in the review cycle. This PEWR was evaluated to that revision.
A Memorandum of Concurrence was not submitted by the plant operations representative to communicate the plant's concurrence as required by Procedure EMP-014, Project Reviews. If receipt of the concurrence memo does not occur within four weeks from the completion of the PEDR, the project engineer is required to notify in writing the Plant Vice President and Vice President Technical Functions that further progress on the specific modi-fication is terminated pending receipt of plant concurrenc This was not accomplishe The PEDR chairman for the modification was the Electrical Power Manager, the responsible manager for this particular modifica- '
tion. Procedure EMP-014, Project Reviews, requires that the formal members of the PEDR board, as defined in EMP-14, not be involved in the engineering or managing the engineering of the design package being reviewe The PEDR was conducted by mail as allowed by EMP-14, but no distinction is made regarding the PEDR chairman eligibility if the review is conducted by mai EMP-14 was not adhered to regarding the PEDR chairman eligibilit The Operability / Maintainability /Constructability Review (OMCR)
was conducted on 1/15/86 in accordance with EMP-14. EMP-14 requires mandatory participation by Plant Operations, Plant '
Maintenance / Material, Maintenance and Construction (M&C),
Startup and Test, Radiological Engineering, GPUNC Quality Assurance (QA), and the project and design engineers. In
      '
addition to the project and design engineers the following organizations were represented: Maintenance and Construction (contract employee), Startup and Test, and Plant Engineerin QA was not represented, but did provide written comments after the meeting. Plant Operations was not directly represented, although Plant Engineering was in attendance. Plant Maintenance / Material and Radiological Engineering were not presen The PEDR meeting was conducted by issuing the preliminary design package for review and comment in accordance with EMP-14. The project engineer received comments from the following organizations: Plant Operations, Plant Engineering, and Startup and Test. The preliminary design package received much wider distribution and Startup and Test, QA Engineering, System Engineering, MC&F, Planning and Scheduling, Engineering Projects, BWR licensing, M&C Technical Support, M&C Workload and Control Support, Engineering and Design, Maintenance Engineering, Operations Engineering, M&C Planning, Mechanical Systems, and Quality Assurance and Engineering Configuratio a
.
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17  -
9.8 The drywell thermocouple modification (BA 328145) was initiated to improve the drywell temperature sensing capabilities in the reactor head flange area. Previous thermocouples mounted in this area pro-vided less than optimum indications as a result of their particular
'
mounting device. This modification is intended to seismically mount two upgraded thermocouples that will provide accurate drywell temper-ature readings. The modification was conducted in accordance with the mini-mod procedure EMP-002 as authorized by a letter from the Director Engineering and Design dated November 25, 1985. Similar procurement and design documentation was reviewed for this modifica-tion as was accomplished for BA 402786.


. The following concerns were identified as a result of this review:
The assignment of a priority two did not create a situation where the review of the PEWR was delayed. Per procedure 125, revision 3, priority (Category) two assumes the definitions previously designated as priority one. Priority one is now reserved for those tasks "which left undone, would require the plant to shut down (if
--
An OMCR meeting was conducted on January. 29, 1986 in accordance with procedure EMP-014. The following organizations were repre-sented at the meeting: Plant Engineering, Maintenance and Con-struction, and the project and design engineers. Although not present at the meeting, Startup and Test did send a "to comments" memoranda to the project engineer. EMP-014 requires mandatory participation by the organizations delineated in EMP-011. Not all of the required organizations were represente The drywell thermocouple modification is being conducted as non-environmentally qualified (EQ). The licensee considers the thermocouples associated with the Gemac reactor vessel water level reference leg as the required instrumentation to measure j drywell atmospheric temperature. The water level reference leg thermocouples' primary purpose is to provide indication of ref-erence leg flashing and, therefore, an indication of correct reactor vessel water level readings. The licensee has conducted some analysis to indicate that these reference leg thermocouples could provide drywell atmosphere temperature indication. Regu-latory Guide 1.97 requires drywell atmosphere -temperature instru-
,
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operating) or prevent plant startup (if in shutdown)". Also a
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'
mentation to be qualified as category 1 under equipment qualifi-cation. The licensee document, TDR 528 requires drywell temper-ature to be qualified to category The licensee is in the process of revising their commitment in TOR 528 by developing a new document that will require drywell atmosphere temperature to be qualified to category 2. TDR 528 (June 1984) was written in response to Generic Letter 82-33. An order confirming this commitment was issued in June 198 TDR 528 indicated that drywell temperature is a direct indication of approaching design temperature limits which could lead to
priority one classification does not necessarily imply "imediate c; tion",
 
f or immediate corrective action, a Technical Functions Work Request (#86-47) was written for an evaluation of the use of mobile cranes with respect to NUREG 0612.
violation of the safety function of preserving primary contain-ment integrity. Also, drywell temperature is an entry condition to the Emergency Operating' procedures and an action level to initiate containment spray and scram the reactor. The safety functions are reactor coolant integrity and containment integrity.
 
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The licensee's revised document states that the reactor water j level cold reference leg temperatures are indicative of drywell temperatures. Due to their locations and post accident drywell
Further corrective action was taken to revise and further define task priorities in procedure 125, Conduct of Plant Engineering.
;
conditions, plant analysis indicates that these thermocouples are representative of drywell temperature. TDR 528 also indi-cated that drywell temperature was in compliance with EQ require-ments and that the licensee planned to upgrade the system during 11 In addition, the TDR indicated that a system for measuring i drywell bulk temperature did not exist. The environmental quali-fication requirements for drywell atmosphere . temperature elements will be clarified in further discussions with the license This will remain an unresolved item. (219/86-06-05).


9.C The recirculation valve interlock modification (BA 402207) resulted from corrective action to address a low low low reactor water level condition that occurred in May 1979. On 5/2/79 an inadvertent 1 reactor high pressure scram occurred during surveillance of the 1- isolation condenser high pressure initiation switches. The high pressure signal inadvertently induced during the surveillance also caused all 5 recirc pumps to trip. Operator action resulted in isolation of the five recirc loops which broke the continuity between the core region and annulus region. Because reactor water level instrumentation sensors connect to the annulus region, there
This action was completed on June 13, 1986.


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was no indication of actual water level in the core until the triple low level alarm occurred. (Triple low alarm signal is generated from different instrument lines that sense water ' level in the core region.) A licensee investigation determined it is necessary to maintain a minimum of two recirc loops open to preclude this type of
l l
'; scenario. This was consistent with Tech Spec requirements which also requires a minimum of two loop operation. The decision was 3 made to install an interlock scheme to prevent isolating more than 3 j loops. Subsequent to the licensee's investigation, the NRC issued NUREG-0660 and 0626 that also required this type of an interlock to i be installe Over 6 years later, corrective action will be implemented during the 11R outage when an alarm will be installed to alert the operators when the fourth recirc loop is isolated. The replacement of an interlock scheme to prevent less'than 3 loop operation to an alarm
,. - - . - - _ __ - _ _ _ . _ . _ __ __ _
!.
_ _ _ _ _ _ _ _ _
that activates when the fourth loop is . isolated represents a i substantial scope change.' The inspector questioned the licensee
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about the scope change, alarm logic, and the lengthy delay in i implementation of the corrective action. The licensee referred to i
NRC Licensing correspondence that tracked the changes.and delays, f
f


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ATTACHMENT 11
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      .
Violation B:
10CFR50, Appendix B, Criterion V and Section 3 of the Oyster Creek Operation Quality Assurance Plan require, in part, that activities affecting quality be prescribed by and accomplished in accordance with documented instructions, procedures, and drawings.


The following documents, in addition to others, were reviewed:
Contrary to the above, as of March 27, 1986, the licensee failed to:
  --
   (1) Follow the requirements of Technical Functions procedure EMP-014, Rev.1-01, Project Reviews, by not issuing a Memorandum of Concurrence for modification packages BA 402786 and BA 402775.
Design Criteria 391-80-3 dated 9/12/80
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Engineering Evaluation 391-80-1 dated 7/29/80
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Installation Specification 391-80-4 dated 3/20/81
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Modification Proposal 391-80-2 dated 8/18/81
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Installation Specification 391-80-5 dated 12/10/81
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Request for Project Approval dated 2/14/86
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OMCR Meeting Conference Notes No. 59 dated 10/16/85
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TOR 528, Rev. 1, Oyster Creek Reg Guide 1.97 Implementation
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Construction Release Checklist dated 11/4/85
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Installation Specification OCIS-402207-001 dated 11/4/85
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GPUN Drawing E0447, Rev. 2, Elementary Diagram Recirculating Loop Annunciator Logic
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Fire Hazards Analysis Input and Status, FPE No. OC-402207-001, Rev.0, dated 11/5/85
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Procurement Release Checklists - various
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Purchase Orders - miscellaneous
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Burns and Roe Work Order 3731-46
  --
GPUN Tech Spec for A/E Engineering and Design Services,
                  '
SP-1302-56-082 dated 5/9/85
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System Design Description (SDD) Div. 1 for Recirc Valve Interlock Modification, SDD OC-6278 dated 8/30/85
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SDD OC-6278, Rev. 2, Div. II dated 9/9/85
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Nuclear Safety / Environmental Impact Evaluation Summary Sheet for Recirc Valve Interlock Modification, SE No. 402207-001, dated 9/18/85
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Work Authorization 415A-30207
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PEDR Review conducted 8/8/85 The documentation file on this modification was quite lengthy based on the long history. Various correspondence documented licensee commitments to the NRC to implement an interlock scheme. It was not until just before the start of the 11R outage that the licensee
                ~
received relief from NRC Licensing to change the scope of the modification. The engineering for the alarm modification was performed by Burns and Ro The following concerns were identified as a result of this review:
  --
The inspector questioned the alarm logic in that it would seem more appropriate to alarm when 3 loops are isolated. This could prevent isolating a fourth loop. This would appear to be more consistent with the requirements in the Tech Specs and the intent of the original requirement for an interlock that would prevent isolating a fourth and fifth lonp. The NRC inspector pursued this concern with NRC Licensing who stated they reviewed the licensee's logic and found it acceptabl u_________._______.______ _ . _ _ _ _ _ _ _ . _ _ _ _ . _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ . . _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . . _ _


.
(2) Assign a Preliminary Engineering Design Review Chainnan for BA 402786 who was independent of the engineering or managing of the design package as required by EW-014.
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(3) Enforce the mandatory attendance requirements for the Operability, Maintainability, and Constructability Review for BA 402786 and BA 402775.
Paragraph 6.1 of the System Design Description (SDO) stated a Class IE surveillance and ISI program for the new relays should be implemented and should be consistent with the existing pro-gram for similar Class 1E relays in the Control Room. The in-spector requested a specific procedure be referenced, if there is one, or the statement be delete The licensee stated they interded to delete the-statemen The inspector requested clarification of a-jumper that appears on drawing E0501 in that it was not clear from either the drawing or the related documentation whether the jumper was existing or new. The licensee agreed to state in the SDD that a jumper must be added as part of the circuit to supply 125VDC control power to the alarm reflash uni Similarly, as discussed in paragraphs A and B above, not all participants required by EMP-014 were in attendance at the OMC Based on certain memos in the file, it became apparent that Plant Operations was not responsive to the PEDR process in that they did not attend the PEDR nor did they comment within 4 weeks as required by EMP-014. The inspectors asked Tech Functions management if this was a chronic problem and were informed it had been a problem in the past but had recently improve The inspectors were concerned about the time delay in implementing the corrective action to the 5/2/79 even Other potential concerns were raised during the review and were satisfactorily addressed by the license .0 The Emergency Diesel Generator (EDG) lube oil modification (BA 402775)
resulted from a recommendation by both the NRC in. Circular 79-12 and the manufacturer, GM-EMD, to accomplish improved lubrication capacity to the turbo charger and main engine components. The recommended modifications are intended to:
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Eliminate engine bearing potential failure Reduce maintenance by continual oil replenishment of the oil
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cooler and filters to full level regardless of oil temperature and viscosity
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Remove restart restrictions imposed on unit surveillance an ,
test schedules
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Provide consistent oil circulation through the engine crankshaft bearings
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Provide consistent circulation through the turbo charger bearings
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Vent trapped air which may impede oil flow through the system.


i
(4) Properly schedule the Responsible Technical Review prior to the Safety Evaluation for BA 402775 as required by Tech Functions
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Procedures LP-009, Rev.1-00, Independent Safety Reviews and EP-016, Rev. O, Nuclear Safety / Environmental Impact Evaluations.


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Response:
 
  (1) GPUN concurs in the violation.
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4 Oyster Creek is one of the last owners of turbo charged EMD MP45 diesel generators to accomplish this modification. GPUN considers the modification an improvement and, therefore, not urgent and, there-fore, the time delay in implementation. The decision to implement the modification at this time is most likely due to recent problems experienced with the #10 bearing on the #1 EDG. The modification adds an AC and DC lube oil pump, increases some pipe sizes, adds vents, and adds an improved design lube oil cooler core. The bulk of the design and installation work has been contracted to Power Systems with some electrical work contracted to Burns and Roe. Power Systems will provide technical direction of installation including supervision of crafts and labo The following documents, in addition to others, were reviewed:
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Tech Functions Work Request (TFWR) A00642 to evaluate and implement modifications as recommended by GM-EMD
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Croneberger Memo dated 11/19/85, E&D/0C-2426, invoking mini-mod ,
process for this modification  1
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Oyster Creek Installation Specification 402775-001, Rev. 1, Oyster Creek EDG Lube Oil Modification
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Request for Project Approval
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Engineering Services Project Cost Estimate
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Project Scope Checklist
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Short Form Specification, SP 1302-12-217, Rev. 1, Lube Oil System Modification Equipment for GM-EMD MP 45 Diesel Generator Units
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PEDR/0MCR scheduling memo date 2/14/86 that scheduled combined PEDR/0MCR for 2/21/86
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Memo MC-86-3603 issued 2/24/86 documenting OMCR meeting on 2/21/86
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Memo 5511-86-034 issued 3/19/86 documenting PEDR meeting on 2/21/86
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Safety Evaluation No. 402775-001, Rev. 1, dated 1/30/8 Subsequently updated on 2/26/86 and 3/17/86. '
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Power Systems Proposal No. 83751
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Fire Hazards Analysis FPE No. OC-402775-001
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Verification General Checklist V-1302-86-001 signed 2/4/86
 
The following concerns were identified as a result of this review:
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The Memo dated 11/19/85 stated that in accordance with paragraph 4.3.7 of EMP-002, the simplified documentation requirements of EMP-002 would be invoked for this project since it satisfies the technical requirements outlined in paragraph 4.1.1 of EMP-002.
 
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What this memo basically did was invoke the " mini-mod" procedure which streamlines the method of modification review and approval 4    by eliminating certain documents and reviews. The inspector reviewed the EDG Lube Oil Modification and the-mini-mod require-ments discussed in EMP-002 paragraph 4.1.1 and determined that this modification does not satisfy the stated technical require-ment In discussions with GPUN Tech Functions management regarding this discrepancy, it was concluded the Director-Engineering and Design does not need to meet 4.1.1 requirements to invoke the mini-mod process. The licensee committed to revise the standard memo used to invoke the m.ni-mod process to eliminate confusion in the futur l
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The Project Sccpe Checklist stated no FSAR revision was i    required. A review of the modification package made it quite clear, as well as did the Safety Evaluation, that a FSAR change is required. Subsequent to inspector identification of this discrepancy, the Project Scope Checklist was correcte Review of Fire Hazards Analysis FPE No. OC-402775-001 disclosed
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that it did not evaluate the impact of the addition of the two new motors. Subsequent to inspector identification of this
<
discrepancy, the licensee committed to amend the analysis to


include the two additional motor EMP-014 requires a Memorandum of Concurrence as a vehicle for communicating the plant's concurrence with operability and main-tainability of modification. A review of the documentation
i l  The project engineers neglected to require a memo of concurrence and this omission was not detected by the Project Manager. All involved personnel were reminded of the procedural requirement to receive such a memorandum within 4 weeks of the PEDR.
.
files indicated no Memorandum of Concurrence (M of C) was


written. When the inspector pointed this out to the licensee, he stated he believed that a M of C did exist and it would be made available to the inspector for review. Subsequent to this statement, the licensee stated a M of.C was not required and, therefore, was not written because the mini-mod process had been invoked. A review of licensee procedures did not appear to preclude the need for a M of C, especially in light of the fact
Since the NRC review, memos of concurrence have been received for both projects.
,
that a PEDR was conducte EP-008 discusses requirements for Comment . Resolution Form These forms are to be used by each organization to transmit
,    their comments in the PEDR and OMCR review processes. Although
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the Comment Resolution Forms do not become pa'rt of the permanent
:
_______.______ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ __ _ ____ _ _ ___ _ ____ _ _.___ _ _____ _ __ _ __ _ ___________.___ _ __________ _______ _


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Full compliance was achieved on June 18, 1986.
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plant records (except if PEDR is by mail), a review of the per-manent and non permanent records indicated most organizations involved in the PEDR and OMCR review processes had no comments as evidenced by a lack of Comment Resolution Forms. The inspec-tors asked the licensee if it was the intent that if a reviewing organization had no comments they should so indicate on the Comment Resolution Form and return it. The licensee stated this was not a requirement and was not generally done. Based on this methodology for soliciting comments as part of the PEDR and OMCR processes, the inspectors could not conclude that participating organizations are actively taking part in the review proces The controlling procedures for the Tech Functions review pro-cesses do not specify what constitutes a quorum. The procedures do require that specific organizations be invited to a PEDR and mandatory attendance at the OMC Reviews of the attendance sheet for the combined PEDR/0MCR indicated that participation was less than required by EMP-014. The inspectors asked the licensee what constituted a quorum as not all required or in-vitec participants attend the OMCR and PEDR meetings. The li-censse stated that there was no quorum and that the chairman of the meeting was responsible for cancelling the meeting if in-sufficiently attended. The inspectors asked if a PEDR or 0MCR meeting had ever been cancelled due to insufficient attendanc The licensee stated they could not recall this ever happenin Tha lack of enforcement of procedural requirements per EMP-014 fr.r mandatory attendance and the lack of a definition for a q;orum, led the inspectors t.o conclude that the PEDR and OMCR eview processes may not be as comprehensive as intende The inspector asked the licensee if, after completion of the EDG Lube Oil Modification, the lube oil system would be flushe The licensee stated they do not intend to flush the system but will rely on Dermar,ent system filters to remove particulate left from the construction activit Procedures LP-009 and EP-016 direct that the Responsible Techni-cal Review (RTR) be completed before the Safety Evaluation (SE)
(2) GPUN does not concur in the violation.   ,
is performed. In the case of the EDG Lube Oil Mod, it appears there were two RTRs -- one before and one after the SE. The
GPUN disagrees that this finding is not in accordance with procedure EW-014. The detailed engineering for this project was assigned to General Electric, the manufacturer of the transformers. As such, the GPUN responsible manager was not directly responsible for managing the engineering details and, therefore, was eligible to function as the PEDR Chainnan; i.e.,
; reason for sequencing the SE after the'RTR is to provide a total i
RTR. In this case, the responsible manager did not compromise his RTR responsibilities of ensuring that "all the appropriate engineering concerns and safety considerations (were) addressed during the design process."
picture to the individual doing the SE. The-procedures do not address updating the SE if a RTR held af terwards results in comments. Procedure LP-009 states that revisions to SEs are not appropriat It is not clear what constitutes a revision, but it wo.ild seem appropriate that if a RTR held after the SE
; resulted in comments, that the individual who performed the SE
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would be informed to determine if there was any impact on his S This was not accomplished for this med in that the first RTR and the SE were dated nearly three weeks before the second RTR (PEDR)
and there was no evidence of a subsequent SE by the reviewer.


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The above concerns contain examples of failure of the licensee to follow procedure In summary the licensee failed to:
   (1) Follow the requirements of EMP-014 by not issuing a M of C in two of the four packages reviewe (2) Assign a PEDR chairman who was independent of the engineering or managing of the design package as required by EMP-014 for the transformer fan cooling modificatio (3) Enforce the mandatory attendance requirements for the OMCR as required by EMP-014.
 
i (4) Properly schedule the RTR prior to the SE as required by LP-009 and EP-016 for the EDG Lube Oil Modification.
 
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These four examples of failure to follow procedures are contrary to the
; requirements of Criterion V of 10 CFR 50 Appendix B and represent a
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single violatio (219/86-06-06)
The inspectors were also concerned with the substantial time delay between identification of the need for a modification and final implementatio Although the licensee appears convinced that the delays are unavoidable, the fact remains that six years would appear excessiv The synergistic effects of a group review of modifications is obviously appreciated and intended as demonstrated by the procedural requirements governing the process. However, the lack of total participation would seem to detract from the licensee's goa . Management Meeting A nanagement meeting was held to discuss the present status of work as-
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sociated with IE Bulletin 79-02 and 79-14 on April 1, 1986 in the NRC Regional office. GPUN Technical Functions Division presented information providing the status of 79-02 and 79-14, schedule and plans for future
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work to be conducted, and analysis regarding current system operabilit The licensee stated they had deleted the requirement from their inspection program to determine as found torque on concrete expansion' anchor bolt The licensee is going to submit meeting minutes to the regional office for
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Concurrenc . Observation of Physical Security During daily tours, the inspectors verified access controls were in I accordance with the Security Plan, security posts were properly manned, ;
protected area gates were locked or guarded, and isolation zones were
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l free of obstructions. The inspectors examined vital area access points l to verify that they were properly locked or guarded and that access control was in accordance with the Security Plan.
 
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  . l (3) GPUN concurs in the violation.


A portion of the security system was taken out of service because of an i equipment malfunction. Although compensatory measures were taken, they
The intent of procedure EW-014 is to ensure that all appropriate groups have the opportunit{ to participate in OMCR meetings. The term " mandatory attendance in the current version of EW-014 is being revised to say that it is mandatory that all appropriate groups be " invited".
; were not in accordance with Security Plan requirements. The discrepancy l was self-identified by the licensee a short time later and corrected.


t After identification of the problem, a search of various areas of the i plant was conducted to ensure no security breeches occurred. The inspec-
Full compliance will be achieved when the revision to EW-014 is issued, presently projected for December 1,1986.
! tors reviewed licensee response to the event and corrective action to preclude recurrence. No concerns were identified.


t
(4) GPUN concurs in the violation.
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During this report period, the licensee implemented a drug and alcohol control program. It is based on a random sampling technique for most employees and a 100% check on certain critical employees.


I 12. -Unusual Event: Bomb Threat i At 4:35pm on March 24, 1986 the plant telephone operator reported receiving a bomb threat on an outside line. The licensee declared an Unusual Event
In this situation, the Project Engineer did not recognize that the '
.i at 4:54pm and responded appropriately in accordance with their procedures.
PEDR Chairman served the role of RTR. The Safety Evaluation (Rev.


] A search of the site and plant spaces was completed prior to ending the Unusual Event.
0) was consequently initiated and signed off by both the RTR (different from the PEDR Chairman) and ISR weeks before the scheduled PEDR Meeting. As a result of the PEDR Meeting, the Safety Evaluation was revised (Rev.1) and the document was properly noted and signed off by the PEDR Chairman. (It should be noted that the PEDR Chairman recognized his responsibility to ensure that the PEDR Process addressed the entire Safety Evaluation and not just the changes from Rev. O to Rev.1.) At the time of the NRC review, the revised Safety Evaluation had not been re-reviewed by the ISR to determine if the changes had a safety significance. Since that time, however, the Safety Evaluation (Rev. 1) has received another ISR and was found to be acceptable.


l i 1 Briefings During this inspection period, the resident inspectors attended briefings on the following topics:
The personnel involved with.this project have been instructed in the proper handling of Safety Evaluations and changes thereto.
  --
Powershape Monitoring system-
  --
Quality Assurance Annual Review i
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Inservice Inspection schedule for cycle 11 refueling outage
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Work Management System i
! The inspectors found the briefings to be informative.
:
1 14. Exit Interview
      -
I A summary of the results of the inspection activities performed during
] this report period were made at meetings with senior licensee management i at the end of the inspection. ..The licensee stated that, of the subjects -
      '
] dhscussedattheexitintervf'ew,noproprietaryinformationwasinclude During the telephone exit with, Technical Functions, the licensee indicated
,
that he might be able to provide additional information.or documentation j- to alleviate some of the concerns in Detail 9. Upon receiving no ad- ,
; ditional documentation or pertinent information af.er ten days, the inspec-tor' reconfirmed to the licensee the disposition of the findings.


"
Full compliance was achieved on June 13, 1986 when the ISR on Revision 1 to the Safety Evaluation was completed.
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(0194A)
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Revision as of 17:12, 26 December 2020

Ack Receipt of 860624 Ltr Denying Violation Noted in Insp Rept 50-219/86-06 Re Assignment of Individual as Preliminary Engineering Design Review Chairman Not Independent of Engineering of Design Package.Violation Valid
ML20207J582
Person / Time
Site: Oyster Creek
Issue date: 07/24/1986
From: Starostecki R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Fiedler P
GENERAL PUBLIC UTILITIES CORP.
References
NUDOCS 8607290177
Download: ML20207J582 (2)
v • d • e


Text

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JUL 2 41986 Docket No. 50-219 GPU Nuclear Corporation ATTN: Mr. P. B. Fiedler Vice President and Director Oyster Creek Nuclear Generating Station P. O. Box 388 Forked River, NJ 08731 Gentlemen:

Subject: Inspection 50-219/86-06 In your letter of June 24, 1986 regarding our inspection report 50-219/86-06, you took issue with Violation B(2). This matter has been brought to my atten-tion because you stated that you did not agree with the violation.

This matter involved the assignment of a Preliminary Engineering Design Review (PEDR) Chairman for the 480 volt vital transformer cooling fan modification, BA402786, who was not independent of the engineering or managing of the design package as required by Technical Functions Division Procedure EMP 014, Project Reviews. In your response you stated the detailed engineering for this project was assigned to General Electric and, as such, the responsible GPUN manager was not directly responsible for managing the engineering details and, therefore, was eligible to function as the PEDR Chairman. EMP 014 clearly states the PEDR Chairman in the capacity as the Responsible Technical Reviewer (RTR) "shall not have been involved in engineering or managing the design." In this case the PEDR Chairman was responsible for and involved in managing the design of BA402786. Although we recognize that the individual may not have been involved in the " engineering details" as indicated in your response, our view is that the intent of the procedure is to obtain a separate overview of the matter.

It is not clear by your response as to how this separate review was accom-plished. In our view the assigned individual was ineligible to perform the RTR function.

We have evaluated your response and have reviewed again our original findings, concluding the citation is valid. Accordingly, you are required to respond within 20 days of the date of this letter. Your response should explain what corrective steps will be taken to assure that both the intent and spirit of independent review is not compromised.

Thank you for your attention in this matter.

Sincerely, Original S1 8ued By:

Richard W. Starostecki, Director Division of Reactor Projects ag72h77860724CK0500g ;ICIAL RECORD COPY RL OYC 86-06 - 0001.0.0

$ 07/23/86 160I h

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GPU Nuclear Corporation 2 cc w/ encl:

M. Laggart, BWR Licensing Manager Licensing Manager, Oyster Creek Public Document Room'(PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of New Jersey Lcc w/ encl:

Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o encl)

Section Chief, DRP Robert J. Bores, DRSS f / Bateman RI:DRP 9: RI DRP Blough dRI*.DRP Kister R;;DP Starostecki 07/ 17/86 07/G/86 07d86 07g986 0FFICIAL RECORD COPY RL OYC 86-06 - 0002.0.0 07/23/86

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GPU Nucioer Corporation

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NQQIgf Post Office Box 388 Route 9 South Forked River.New Jersey 087310388 609 971 4000 Wnter's Direct Dial Number:

June 24, 1986 Mr. Harry B. Kister, Chief Projects Branch No. 1 U.S. Nuclear Pegulatory Connission Region I 631 Park Avenue King of Prussia, PA 19406

Dear Mr. Kister:

Subject: Oyster Creek Nuclear Generating Station Docket No. 50-219 IE Inspection Report 86-06 Attachments to this letter provides GPU Nuclear's responses to the identified violations in Appendix A of your letter dated May 12, 1986. As receipt of this report was delayed 9 days, an extension of the due date to June 25, 1986 was granted by the Resident Inspector at the Oyster Creek Station.

If any further information is required, please contact Mr. John Rogers of ray staff at (609)971-4893.

Very truly yours,

, .

1.g P iedler V e President and Director l Oyster Creek

PBF/JR/ dam

! Attachments l cc: Dr. Thomas E. Murley, Administrator

) Region I

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U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Mr. Jack N. Donohew, Jr.

f U.S. Nuclear Regulatory Connission l

7920 Norfolk Avenue, Phillips Bldg.

l Bethesda, MD 20014 l

c NRC Resident Inspector

! Oyster Creek Nuclear Generating Station l

! -8vo707003 V GPM Nuclear Corrgoration is a subsidiary of the General Public Utilities Corporation

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- ATTACHMENT I Violation A:

Technical Specification 6.8.1 requires that written procedures shall be established, implemented, and maintained. Station Procedure 125, Revision 2, Conduct of Plant Engineering, delineates the functions, responsibilities, authorities, and organizational interfaces of the Plant Engineering organization. Paragraph 6.4 of this procedure requires that Plant Engineering tasks be prioritized and those tasks deserving issnediate attention assigned a priority one rating. The procedure requires, in part, that a priority one rating be given to thoses tasks which, left undone, would cause a NRC commitment deadline to be missed.

(1) Contrary to the above, as of April 3,1986, Station Procedure No.

125 was not being maintained, as it relates to the tracking of engineering tasks. Significant discrepancies existed between procedural descriptions and requirements and the way the Plant

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Engineering organization was conducting activities. These discrepancies included the following areas: (1) description of the organization and responsibilites; (2) the performance of engineering tasks, including the initial review and assignment of engineering tasks, acknowledgement to the requestor, and the close out of tasks including response to the requestor; (3) the maintenance of records; and (4) the prioritization of plant engineering task assignments.

(2) Contrary to the above, as of April 4,1986, Station Procecure 125 l

was not adequately implemented, in that a Plant Engineering Work Request written August 19, 1985 by the Plant Materiel Department

and received by P.lant Engineering on August 20, 1985, had been

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given a priority two rating and was not scheduled for review. The

,

issue involved lack of plans and procedures governing movement of

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heavy loads (NUREG-0612) using a portable crane at the intake structure in the vicinity of the emergency service water pumps. A Safety Evaluation, in part, documenting the licensee's consnitments regarding movement of heavy loads, was issued June 21, 1983. In this document it was explained that movement of heavy loads at the intake was not a concern because the intake gantry crane had been

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removed but that, if at some time in the future this crane is placed back in service, an evaluation would be performed to ensure that NUREG-0612 criteria are satisfied. Although the gantry crane has not been placed in service, the use of a portable crane to move heavy loads is an equivalent situation.

Response:

(1) GPUN concurs in the violation.

Insnediate corrective action was taken to initiate a revision to Procedure 125. The requisite organizational description and j

delineation of responsibilities were revised and clarified. The engineering request tracking system description was updated to more i

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accurately describe the system presently in place listing engineering requests and tracking them to completion. The requirements for records management were revised to align with GPUN commitments to ANSI Standards. The prioritization methodology was redefined and fonnally proceduralized.

Full compliance was achieved with the issuance of Revision 3 to Procedure 125 on June 13, 1986.

(2) GPUN concurs in the violation.

The identified Plant Engineering Work Request (PEWR) was not evaluated in compliance with revision 2 of procedure 125 in effect at the time. However, the philosophy for prioritization had been modified, and a revision to procedure 125 had been initiated and was in the review cycle. This PEWR was evaluated to that revision.

The assignment of a priority two did not create a situation where the review of the PEWR was delayed. Per procedure 125, revision 3, priority (Category) two assumes the definitions previously designated as priority one. Priority one is now reserved for those tasks "which left undone, would require the plant to shut down (if

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operating) or prevent plant startup (if in shutdown)". Also a

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priority one classification does not necessarily imply "imediate c; tion",

f or immediate corrective action, a Technical Functions Work Request (#86-47) was written for an evaluation of the use of mobile cranes with respect to NUREG 0612.

Further corrective action was taken to revise and further define task priorities in procedure 125, Conduct of Plant Engineering.

This action was completed on June 13, 1986.

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ATTACHMENT 11

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Violation B:

10CFR50, Appendix B, Criterion V and Section 3 of the Oyster Creek Operation Quality Assurance Plan require, in part, that activities affecting quality be prescribed by and accomplished in accordance with documented instructions, procedures, and drawings.

Contrary to the above, as of March 27, 1986, the licensee failed to:

(1) Follow the requirements of Technical Functions procedure EMP-014, Rev.1-01, Project Reviews, by not issuing a Memorandum of Concurrence for modification packages BA 402786 and BA 402775.

(2) Assign a Preliminary Engineering Design Review Chainnan for BA 402786 who was independent of the engineering or managing of the design package as required by EW-014.

(3) Enforce the mandatory attendance requirements for the Operability, Maintainability, and Constructability Review for BA 402786 and BA 402775.

(4) Properly schedule the Responsible Technical Review prior to the Safety Evaluation for BA 402775 as required by Tech Functions

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Procedures LP-009, Rev.1-00, Independent Safety Reviews and EP-016, Rev. O, Nuclear Safety / Environmental Impact Evaluations.

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Response:

(1) GPUN concurs in the violation.

i l The project engineers neglected to require a memo of concurrence and this omission was not detected by the Project Manager. All involved personnel were reminded of the procedural requirement to receive such a memorandum within 4 weeks of the PEDR.

Since the NRC review, memos of concurrence have been received for both projects.

Full compliance was achieved on June 18, 1986.

(2) GPUN does not concur in the violation. ,

GPUN disagrees that this finding is not in accordance with procedure EW-014. The detailed engineering for this project was assigned to General Electric, the manufacturer of the transformers. As such, the GPUN responsible manager was not directly responsible for managing the engineering details and, therefore, was eligible to function as the PEDR Chainnan; i.e.,

RTR. In this case, the responsible manager did not compromise his RTR responsibilities of ensuring that "all the appropriate engineering concerns and safety considerations (were) addressed during the design process."

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. l (3) GPUN concurs in the violation.

The intent of procedure EW-014 is to ensure that all appropriate groups have the opportunit{ to participate in OMCR meetings. The term " mandatory attendance in the current version of EW-014 is being revised to say that it is mandatory that all appropriate groups be " invited".

Full compliance will be achieved when the revision to EW-014 is issued, presently projected for December 1,1986.

(4) GPUN concurs in the violation.

In this situation, the Project Engineer did not recognize that the '

PEDR Chairman served the role of RTR. The Safety Evaluation (Rev.

0) was consequently initiated and signed off by both the RTR (different from the PEDR Chairman) and ISR weeks before the scheduled PEDR Meeting. As a result of the PEDR Meeting, the Safety Evaluation was revised (Rev.1) and the document was properly noted and signed off by the PEDR Chairman. (It should be noted that the PEDR Chairman recognized his responsibility to ensure that the PEDR Process addressed the entire Safety Evaluation and not just the changes from Rev. O to Rev.1.) At the time of the NRC review, the revised Safety Evaluation had not been re-reviewed by the ISR to determine if the changes had a safety significance. Since that time, however, the Safety Evaluation (Rev. 1) has received another ISR and was found to be acceptable.

The personnel involved with.this project have been instructed in the proper handling of Safety Evaluations and changes thereto.

Full compliance was achieved on June 13, 1986 when the ISR on Revision 1 to the Safety Evaluation was completed.

(0194A)

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