ML20249B312

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-219/98-80 on 980422

ML20249B312
Person / Time
Site:	Oyster Creek
Issue date:	06/15/1998
From:	Eugene Kelly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Roche M GENERAL PUBLIC UTILITIES CORP.
References
50-219-98-80, NUDOCS 9806220308
Download: ML20249B312 (2)

See also: IR 05000219/1998080

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Mr. Michael B. Roche

.Vice President and Director

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' GPU Nuclear, Inc.

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Oyster Creek Nuclear Generating Station

P.O. Box 388

Forked River, New Jersey 08731

SUBJECT:

INSPECTION REPORT 50-219/98-80 - REPLY

Dear Mr. Roche:

This letter refers to your May 22,1998 corregnondence, in response to our April 22,1998

letter.

.Thank you for informing us of the corrective and preventive actions documented in your

letter .These actions will be examined during a future inspection of your licensed program.

Your cooperation with us is appreciated.

Sincerely,

Eugene M. Kelly, Chief

Systems Engineering Branch

Division of Reactor Safety

Docket No. 50-219

cc w/ encl:

M. Laggart, Manager, Licensing and Vendor Audits

G. Busch, Manager, Nuclear Safety and Licensing

State of New Jersey

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Mr. Michael B.' Roche

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Region i Docket Room (with concurrences)

Nuclear Safety information Center (NSIC)

PUBLIC

NRC Resident inspector

M. Evans, DRP

N. Perry, DRP

D. Haverkamp, DRP

C. O'Daniell, DRP

J. Yerokun, DRS

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B. McCabe, OEDO

C. Thomas, PD1-3, NRR

R. Eaton, PD1-3, NRR

T.- Colburn, PDI-3, NRR

DOCDESK

Inspection Program Branch, NRR (IPAS)

DRS File

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DOCUMENT. NAME: G:\\ SYSTEMS \\YEROKUN\\0C9880. REP

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• E" = Copy with attachment / enclosure

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GPU Nuclear,inc.

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. U.S Route #9 South

NUCLEAR

Post Office Box 388

Forked Rwer, NJ 08731-0388

Tel 609-9714000

May 22, 1998

1940-98-20273

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' U. S. Nuclear Regulatory Commission

Attention: Document Control Desk

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Washington,DC 20555

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Dear Sir:

Subject:

Oyster Creek Nuclear Generating Station

Docket No. 50-219

IR 98-080: Reply to Notice of Violations

In accordance with 10CFR 2.201, the enclosed provides GPU Nuclear's response to the violations

identified in the subject inspection report.

Ifyou should have any questions, or require further information, please contact Brenda

DeMerchant, Oyster Creek Regulatory Affairs Engineer, at 609-971-4642.

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Very truly yours,

) Geh'

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Michael B. Roche

Vice President and Director

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Oyster Creek

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' Administrator, Region I

NRC Project Manager.

NRC Sr. Resident Inspector

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Attachment 1

Response to Notices of Violation

Violation A

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' Technical Specification (TS) 3.4.B.1 requires that: "Five electromatic relief valves of the

automatic depressurization' system shall be operable when the reactor water temperature is

greater than 212 degrees F and pressurized above 110 psig, except as specified in 3.4.B.2.

The automatic pressure relief function of these valves (but not the automatic

depressurization function) may be inoperable or bypassed during reactor vessel p'ressure

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testing consistent with T.S.1.39 and 3.3.A.(I)." TS Table 3.1.1, Item G.1 requires High

Daywell pressure instrumentation to be operable to support ADS operability. TS 4.1.1,

item 9 requires' the High Drywell pressure instruments to be channel checked once per

day.

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Contrary to the above, on October 6,1996, when the automatic depressurization function

was required during the Reactor Vessel Pressure Test, GPUN failed to perform the

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required High Drywell Pressure Channel Check in accordance with T.S. 4.1.1. Item 9, and

therefore, failed to ensure' Automatic Depressurization System (ADS) operability as

required by TS 3.4.B.I.

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

Response

GPU Nuclear concurs with the violation as stated. This event is described in detail in LER

98-003, dated March 31,1998.

Reason for Violation:

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The violation occurred because the procedure which controls the Nuclear Steam Supply

System (NSSS) Leak Test does not contain a step requiring performance of drywell

pressure instrument checks. This oversight was due to the drywell being opened to

atmospheric pressure throughout the NSSS Leak Test. All other requirements for ADS

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operability were completed.

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' Corrective Stens That Have Been Taken and the Results Achieved:

The high drywell pressure daily checks were satisfactorily completed shortly after the

NSSS Leak Test when primary containment was placed into effect prior to startup from

the 16R outage.

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Corrective Stens That Will Be Taken to Avoid Further Violations:

The procedure that controls the NSSS Leak Test will be revised to ensure :he required

surveillance testing with regard to ADS is completed. This procedure will be revised by

August 31,1998. In addition, operator training will be provided on this event.

Date of Full Comnliance:

Full compliance was achieved when the high drywell pressure daily checks were

satisfactorily completed shortly after the NSSS Leak Test when primary containment was

placed into effect prior to startup from the 16R outage.

Violation B (li

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10 CFR 50, Appendix B, Criterion V, Instructions, Proceddres, and Drawings, requires in

part that: " Activities affecting quality shall be prescribed by documented instructions,

procedures or drawings, of a type appropriate to the circumstances and shall be

accomplished in accordance with these instructions, procedures, or drawings."

Contrary to the above, GPUN personnel failed to follow established procedures for

calculations and safety evaluations involving safety related activities in the following two

instances:

In early 1996, calculations to support the seismic adequacy of safety-related equipment (to

address issues of NRC Generic Letter 87-02, Revision 1) were not verified as required by

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Procedure EP-06, Revision 3.03.

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Response:

GPU Nuclear concurs with the violation as stated.

Reason for Violation:

The calculation to resolve the outlier for the anchorage of the containment spray heat

exchangers identified during the walkdowns performed in response to GL 87-02 was not

design verified as required by Procedure EP-006. However, the SQUG summary report

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prepared in response to the generic letter stated that the outlier for the containment spray

heat exchangers had been resolved. The reason for the violation is that engineering

personnel did not place appropriate priority on the completion of the design verification

process. Since a calculation had been prepared and since the calculation demonstrated

that the anchorage for the heat exchanger was adequate, priority was placed on

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modifications of components required to resolve other outliers identified in the SQUG

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summary report.

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

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design verification. On February 2,1998, a new analysis of the heat exchanger anchorage

was begun. The design verification for the revised calculation is expected to be complete

by June 30,1998. The calculation continues to show that the anchorage for the heat

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exchangers is adequate.

Corrective Steps That Have Been Taken and Results Achieved:

Subsequent to the identification of the violation, GPU Nuclear determined that additional

calculations for items reported in the SQUG summary report as " . resolved by

subsequent analysis" had not been design verified. Based on these discrepancies, GPU

Nuclear has taken and is planning a number of steps to avoid further violations.

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

and the design verification is expected to be complete by the end of June,1998. The

schedule for completion of the other SQUG calculations is contained in the revised SQUG

summary report previously submitted to the NRC.

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In addition, GPU Nuclear is revising Procedure 1000-ADM-1216.03, " Regulatory

Correspondence Control," to clarify GPU Nuclear's policy regarding when design

verifications are required and when they must be completed. Documents that support

statements / conclusions in submittals to the NRC are to be completed in accordance with

GPU Nuclear procedures. This includes the requirement that a design verification be

completed for all calculations within the scope of the GPU Nuclear Operational Quality

Assurance Plan. The revision of this procedure is expected to be effective by the end of

June,1998. In addition, GPU Nuclear recently revised the corporate calculation

procedure (EP-006), to clearly state that any required design verifications must be

complete prior to release of any calculations. While the revision to EP-006 was not

performed in response to the NOV, it does clarify the GPU Nuclear policy with regard to

the necessity of completing the required design verifications.

Corrective Steos That Will Be Taken to Avoid Further Violations:

Training has been scheduled during the month of June,1998, for all Engineering Support

Personnel. This training will emphasize the importance of and the requirement to

complete design verifications as required by GPU Nuclear policy and procedures. In

addition, GPU Nuclear is presently reviewing other calculations to determine if similar

discrepancies exist.

Date when Full Comnliance Will Be Achieved:

Upon completion of the calculation and design verification to resolve the outliner for the

anchorage of the containment spray heat exchangers, full compliance will be achieved.

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

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Violation B (2)

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10 CFR 50, Appendix B, Criterion V, Instmctions, Procedures, and Drawings, requires in

= part that: " Activities affecting quality shall be prescribed by documented instructions,

procedures or drawings, of a type appropriate to the circumstances ac 1 shall be

accomplished in accordance with these instructions, procedures, or drawings."

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Contrary to the above, GPUN personnel failed to follow established procedures for

calculations and safety evaluations involving safety related activities in the following two

instances:

On February 26,1998, there were numerous examples of non-compliance with Procedure

EP-016, Nuclear Safety / Environmental Determination and Evaluation, which required a -

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printed name and signature for engineer / originator, section manager or project manager

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(for AEs), responsible technical reviewer, independent safety reviewer, and other reviews

as applicable.

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

GPUN Response:

GPU Nuclear concurs with the violation as stated.

Reason for Violation:

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~ This violation occurred when a number ofindividuals failed to fully comply with GPU

Nuclear procedural requirements. In addition, the governing corporate procedure did not

contain this requirement while the implementing procedure for the Engineering Division

contained the requirement.

Corrective Stens That Have Been Taken and the Results Achieved:

A prior self-assessment of the safety review process at Oyster Creek had identified a

number of strengths, good practices and opportunities for improvement. The

opponunities for improvement included changes in process implementation and training.

The lack of consistency between the corporate procedure and the engineering

-implementing procedure and the level of compliance with the requirement to print one's

name in addition to signing were both noted as areas of concern. A report concerning the

" self-assessment findings was widely disseminated to Oyster Creek management.

Ces.weive Stens That Have Been Tabn To Avoid Further Violations:

' The corporate safety review procedure was modified in response to the recommendations

. of the self-assessment report. The effective date of the revision was March 6,1998.

Among the changes made'was a revision to the safety determination and safety evaluation

forms requiring a printed or typed name in addition to a signature. The safety review

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

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Date of Full Compliance:

Full compliance was achieved on March 6,1998 when the above noted revision to the

Corporate Safety Procedure was modified. Training, which includes the procedure

revision, has begun and is ongoing.

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Violation C

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

" Measures shall be established to assure that conditions adverse to quality, such as

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failures, malfunctions, deficiencies, deviations, defective material and equipment, and

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nonconformance are promptly identified and corrected.

Contrary to the above, on February 26,199'8, a seismic deficiency with a containment

spray heat exchanger, that had been identified in late 1996 by the licensee, had not been

adequately corrected.

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

Response:

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GPU Nuclear concurs with the violation as stated.

Reason for Violation:

During the USI A-46 walkdown of the Safe Shutdown Equipment List (SSEL)

components in 1994, the containment spray heat exchanger chain hoists were written up

as program outliers. The outliers pertain to seismic interaction between the chain hoists,

which were hung unrestrained, and the heat exchanger tubing; valves and small bore

piping. A Work Request (WR) was issued and a Job Order (JO) generated to resolve this

outlier. The WR stated that the chain falls be removed or bagged but did not provide any

specific guidance on execution of this activity. The bagging option was chosen, work was

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performed and the 30 closed out on December 6,1996. Engineering was not notified of

this closecut; hence, no engineering verification of this work was performed to verify that

the potential seismic interaction hazard was removed. During January,1998, engineering

reviewed the status of all SQUG outliers and determined that the subject JO was closed.

Engineering was in the process of scheduling the inspection for closeout of the outlier

when the NRC site inspection found the chain hoist violation on the bottom side of the

heat exchanger.

The bagging option from the WR was chosen and was performed on the hoists above the

heat exchangers only. On the underside, the hoists were tied to the heat exchanger, which

is not in accordance with the WR and JO. The deviation from the JO without notification

is the cause for this violation.

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Corrective Steos Taken and the Results Achieved:

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Plant Maintenance was tasked to restrain all hcists and associated chain falls away from

plant components. Engineering was tasked to re. view the final configuration for seismic

verification to ensure the restrained hoists do not pose a potential seismic interaction

' hazard to any existing plant component and to justify any seismic interaction hazard that

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may exist.

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Corrective Steps That Will Be Taken To Avoid Future Violations:

These hoists are used only during maintenance activities pertaining to the containment

spray heat exchangers. The maintenance activities are controlled by GPU Nuclear

Procedure 2400-SMM-3214.02, " Containment Spray Heat Exchanger Cleaning and

Assembly." This procedure has been revised to Revision 8 to include controls on storage

of chain hoists upon assembly of the heat exchangers. The~ configuration described in the

procedure matches the current verified configuration. Compliance with this procedure will

ensure that the violation will not be repeated.

The Date When Full Compliance Will Be Achieved:

Full compliance was achieved on April 27,1998, which is the effective date for Revision 8

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to procedure 2400-SMM-3214.02.

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Violation D

10 CFR 50.59(b)(2) requires, in part, that licensees submit a report containing a brief

description of any changes, tests and experiments (CTE), including a summary of the

safety evaluation of each, annually or along with the UFSAR updates as required by 10 CFR 50.71(e) or at such shorter intervals as may be specified in the license.

Contrary to the above, as of March 12,1998, GPUN did not submit a CTE report for

1983 and 1986 for Oyster Creek Nuclear Generating Station, and the report submitted on

February 16,1998, covered a period of April 1993 to March 1995.

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

Response:

GPU Nuclear concurs with this violation as stated.

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Reason for the Violation:

' GPUN implemented 10CFR50.71 in 1983 and at that time began submitting the summary

10CFR50.59 repon following preparation of the FSAR annual update. Following the

NRC rulemaking that allowed FSAR updates to be submitted on a schedule consisten:

.with the refueling cycle, GPUN adopted the two-year update interval based on the 24

month refueling cycle. At this point, it was thought the 10CFR50.59 summary report

could also be updated on the two year cycle but it was not recognized the report was

required to be submitted with the FSAR update or submitted _ annually instead.

Additionally, the submittal of the report was not captured in department work tracking

processes to assure timely preparation and submittal.

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Corrective Actions Taken:

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A review was conducted of all reports made since 1981 th' rough 1998 to ensure the

information required to be submitted during this time frame has in fact been submitted.

The information required to be reported by 10CFR50.59 has been included in various

reports, although not on the required schedule, except for the information for the period

March 1995 through December 1996. This report is currently in preparation and

corresponds to tiu last update of the FSAR submitted in June of 1997. This report will be

submitted by June 15,1998 and will establish full compliance with the regulations.

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Actions to Prevent Recurrence:

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The scheduled preparation and submittal of the 10CFR50.59 report has been revised to

coincide with the submittal of the FSAR update following completion of the refueling

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outage for each cycle. Administrative functions and processes will be revised to establish

. appropriate tracking milestones and notifications to responsible individuals which will

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assure timely development and submittal in the future.

. Date when Full Comoliance Will Be Achieved:

Full compliance will be achieved upon submittal of the next 50.59 report which is

currently scheduled for the end of June,1998.

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